* * * 

REDACTED FOR PUBLIC RELEASE 

LIMITED OFFICIAL USE - PROPRIETARY INFORMATION 

Audit of the Office of Justice Programs Victim 

Assistance Grants Awarded to the State of 

Washington Department of Commerce,

Olympia, Washington

AUDIT DIVISION 

20-106 

SEPTEMBER 2020 

REDACTED FOR PUBLIC RELEASE 

Redactions were made to the full version of this report for privacy reasons. The redactions are contained 

only in Appendix 5, and are of individuals’ names 

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Executive Summary 

Audit of the Office of Justice Programs Victim Assistance Grants Awarded to the State 

of Washington Department of Commerce, Olympia, Washington 

Objective 

The objective of the audit was to evaluate how the State 

of Washington Department of Commerce (WA DOC) 

Office of Crime Victims Advocacy designed and 

implemented its crime victim assistance program. To 

accomplish this objective, we assessed performance in 

the following areas of grant management: (1) grant 

program planning and execution, (2) program 

requirements and performance reporting, (3) grant 

financial management, and (4) monitoring of 

subrecipients. 

Results in Brief 

As a result of our audit, we concluded that the WA DOC 

did not adhere to some of the award requirements we 

tested, but its Victims of Crime Act (VOCA) plan 

demonstrated adequate progress towards providing 

services to crime victims. We also determined that the 

WA DOC and a State of Washington pass-through 

agency’s practice of indistinguishably funding subawards 

with both VOCA and non-VOCA funds led to the 

commingling of funds at the subrecipient level. We 

found that the WA DOC did not have a comprehensive 

grants administration manual, which may have led to 

some of the issues we noted. The WA DOC was not 

adequately tracking its funding allocation to four VOCA 

priority categories and did not submit accurate Subgrant 

Award Reports. Further, the subrecipients we tested did 

not adequately support $70,207 in expenditures and 

$3,312 in required match. We also identified concerns 

with the WA DOC’s subaward templates and subrecipient 

monitoring. 

Recommendations 

Our report contains 11 recommendations to the Office of 

Justice Programs (OJP) to assist the WA DOC in 

improving its grant management and administration, 

and to remedy questioned costs totaling $73,519. We 

requested a response to our draft audit report from the 

WA DOC and OJP, which can be found in Appendices 4 

and 6, respectively. One of the WA DOC’s pass-through 

agencies also provided a response to our draft report, 

and it can be found in Appendix 5. Our analysis of those 

responses is included in Appendix 7. 

Audit Results 

The U.S. Department of Justice Office of the Inspector 

General completed an audit of four VOCA victim 

assistance formula grants awarded by OJP’s Office for 

Victims of Crime (OVC) to the WA DOC’s Office of Crime 

Victims Advocacy in Olympia, Washington. OVC awarded 

these formula grants, totaling $207,346,094 for fiscal 

years (FYs) 2015 through 2018, from the Crime Victims 

Fund (CVF) to enhance crime victim services throughout 

the state of Washington. As of June 2020, the WA DOC 

had drawn down a cumulative amount of $157,513,522 

from the grants we reviewed. 

Grant Program Planning and Execution – The WA 

DOC and one of its two state-level pass-through 

agencies awarded VOCA and non-VOCA funds 

indistinguishably to subrecipients. As such, the passthrough agencies, as well as subrecipients, did not 

separately account for VOCA funds. The WA DOC lacked 

a comprehensive grants administration manual and a 

standardized procedure for evaluating its competitive 

subaward opportunities. The WA DOC did not ensure 

accuracy and consistency of its subaward templates. 

Program Requirements and Performance 

Reporting – The WA DOC did not accurately capture its 

funding allocation for the four VOCA priority categories 

to ensure compliance with VOCA requirements. 

Additionally, Subgrant Award Reports submitted by the 

WA DOC contained errors. 

Grant Financial Management – We could not 

determine whether the WA DOC and its two passthrough agencies complied with the 5 percent 

administrative expenditures limit. Due to the 

commingled environment at some subrecipients, we 

limited our testing to subawards funded with VOCA 

grants. We found inadequately supported $70,207 in 

subrecipient expenditures and $3,312 in match 

contributions. 

Monitoring of Subrecipients – We found that one of 

the WA DOC’s state-level pass-through agencies could 

enhance its monitoring of safety issues at domestic 

violence shelters. Finally, some of the subrecipients 

were at a risk of non-compliance with service standards 

due to a lack of state-level onsite monitoring plans. 

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AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM ASSISTANCE GRANTS AWARDED TO THE 

STATE OF WASHINGTON DEPARTMENT OF COMMERCE, 

OLYMPIA, WASHINGTON 

TABLE OF CONTENTS 

INTRODUCTION .......................................................................................... 1 

The Grantee ...................................................................................... 2 

OIG Audit Approach ............................................................................ 2 

AUDIT RESULTS.......................................................................................... 4 

Grant Program Planning and Execution .................................................. 4 

Subaward Allocation Plan ............................................................ 5 

Commingling of Subaward Funds ................................................. 6 

Subaward Selection Process ........................................................ 7 

Subaward Requirements ........................................................... 10 

Grants Administration Manual.................................................... 11 

Program Requirements and Performance Reporting................................ 11 

Priority Areas Funding Requirement............................................ 12 

Annual Performance Reports...................................................... 12 

Compliance with Special Conditions ............................................ 13 

Grant Financial Management .............................................................. 14 

Grant Expenditures .................................................................. 15 

Drawdowns............................................................................. 18 

Matching Requirement.............................................................. 19 

Financial Reporting .................................................................. 21 

Monitoring of Subrecipients ................................................................ 21 

Financial Monitoring ................................................................. 22 

Performance Monitoring............................................................ 24 
 

 

 

 

 

 

 

High-Risk Subrecipient ............................................................. 26 

CONCLUSION AND RECOMMENDATIONS....................................................... 27 

APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY.................................. 29 

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS............................... 31 

APPENDIX 3: WASHINGTON STATE CRIME VICTIM SERVICE PROVIDERS .......... 32 

APPENDIX 4: STATE OF WASHINGTON DEPARTMENT OF COMMERCE RESPONSE 

TO THE DRAFT AUDIT REPORT............................................................ 34 

APPENDIX 5: WASHINGTON STATE OFFICE OF CIVIL LEGAL AID RESPONSE 

TO THE DRAFT AUDIT REPORT............................................................ 37 

APPENDIX 6: OFFICE OF JUSTICE PROGRAMS RESPONSE TO THE DRAFT AUDIT 

REPORT .......................................................................................... 41 

APPENDIX 7: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT.................................. 46 
 

 

 

 

 

 

 

 

 

 

 

 

 

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM ASSISTANCE GRANTS AWARDED TO THE 

STATE OF WASHINGTON DEPARTMENT OF COMMERCE, 

OLYMPIA, WASHINGTON 

INTRODUCTION 

The U.S. Department of Justice (DOJ) Office of the Inspector General (OIG) 

completed an audit of four victim assistance formula grants awarded by the Office 

of Justice Programs (OJP), Office for Victims of Crime (OVC) to the State of 

Washington Department of Commerce (WA DOC) in Olympia, Washington. OVC 

awards victim assistance grants annually from the Crime Victims Fund (CVF) to 

state administering agencies. As shown in Table 1, from fiscal years (FY) 2015 to 

2018, these OVC grants totaled $207,346,094. 

Table 1 

WA DOC Victim Assistance Grants for FYs 2015 through 2018 

Award Number Award Date 

Award Period 

Start Date 

Award Period 

End Date Award Amount 

2015-VA-GX-0031 09/17/15 10/01/14 09/30/18 $42,761,431 

2016-VA-GX-0044 09/08/16 10/01/15 09/30/19 48,821,061 

2017-VA-GX-0061 09/28/17 10/01/16 09/30/20 41,060,865 

2018-V2-GX-0046 08/09/18 10/01/17 09/30/21 74,702,737 

Total: $207,346,094 

Note: Grant funds are available for the fiscal year of the award plus 3 additional fiscal years. 

Source: OJP 

Established by the Victims of Crime Act (VOCA) of 1984, the CVF is used to 

support crime victims through DOJ programs and state and local victim services.1 

The CVF is supported entirely by federal criminal fees, penalties, forfeited bail 

bonds, gifts, donations, and special assessments. The OVC annually distributes 

proceeds from the CVF to states and territories. The total amount of funds that the 

OVC may distribute each year depends upon the amount of CVF deposits made 

during the preceding years and limits set by Congress (the cap). 

In FY 2015, Congress significantly raised the previous year’s cap on CVF 

disbursements, which more than quadrupled the available funding for victim 

assistance grants from $455.8 million to $1.96 billion. In FY 2016, Congress raised 

the cap again, increasing the available funding for victim assistance to $2.22 billion. 

In FY 2017, the amount available for victim assistance was $1.8 billion, and 

Congress made another significant raise to the funding limit in FY 2018 to $3.3 billion. 

OVC allocates the annual victim assistance program awards based on the amount 

1 The VOCA victim assistance formula program is funded under 34 U.S.C. § 20103. 

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available for victim assistance each year and the states’ population. As such, the 

annual VOCA victim assistance grant funds available to the WA DOC increased from 

$9.8 million in FY 2014 to $42.8 million in FY 2015. The WA DOC continued to 

receive VOCA grants in excess of $40 million through FY 2017, with another large 

funding increase to $74.7 million in FY 2018. 

VOCA victim assistance grant funds support the provision of direct services – 

such as crisis intervention, assistance filing restraining orders, counseling in crises 

arising from the occurrence of crime, and emergency shelter – to victims of crime. 

OVC distributes these assistance grants to states and territories, which in turn fund 

subawards to public and private nonprofit organizations that directly provide the 

services to victims. Eligible services are efforts that: (1) respond to the emotional 

and physical needs of crime victims, (2) assist primary and secondary victims of 

crime to stabilize their lives after a victimization, (3) assist victims to understand 

and participate in the criminal justice system, and (4) provide victims of crime with 

a measure of safety and security. 

The Grantee 

As the State of Washington’s state administering agency, the WA DOC’s 

Office of Crime Victims Advocacy (OCVA) is responsible for administering the VOCA 

victim assistance program. OCVA is a part of the WA DOC’s Community Services 

and Housing Division serving needs of crime victims by funding programs 

throughout the state that provide support and assistance to victims or survivors of 

crime. As of 2019, two sections of OCVA administer VOCA victim assistance grants 

in specific areas: one section focuses on sexual assault victim services, while the 

other focuses on all other crimes except for domestic violence. In addition, OCVA 

relies on the State of Washington’s Department of Social and Health Services 

(DSHS) and the Office of Civil Legal Aid (OCLA) as pass-through agencies for two 

specific types of victim services: domestic violence and civil legal aid. 

OIG Audit Approach 

The objective of the audit was to evaluate how the WA DOC designed and 

implemented its crime victim assistance program. To accomplish this objective, we 

assessed performance in the following areas of grant management: (1) grant 

program planning and execution, (2) program requirements and performance 

reporting, (3) grant financial management, and (4) monitoring of subrecipients. 

We tested compliance with what we considered the most important 

conditions of the grants. Unless otherwise stated in our report, we applied the 

authorizing VOCA legislation, the VOCA victim assistance program guidelines (VOCA 

Guidelines) and Final Rule, and the DOJ Grants Financial Guide as our primary 

criteria. We also reviewed relevant policies and procedures and interviewed 

personnel of the WA DOC, the DSHS, and OCLA to determine how they 

administered the VOCA funds. We conducted site visits at five VOCA-funded 

2 
 

 

 

1 

Non-profit 

Organization 

-

-

WA DOC 

Subrecipient 2 

Native American 

Tribe 

Subrecipient 3 

Non-profit 

Organization 

Subrecipient 4 

County 

Government 

Subrecipient 5 

Non-profit 

Organization 

subrecipients, listed in Figure 1, interviewed subrecipient personnel, and reviewed 

their records reflecting grant activity.2 

Figure 1 

Judgmentally Selected Subrecipients 

Legend: Funding direct from the WA DOC 

Funding through a state-level pass-through agency 

Source: OIG analysis 

2 Appendix 1 contains additional information on the audit’s objective, scope, and 

methodology, as well as further detail on the criteria we applied for our audit. Appendix 2 presents a 

schedule of our dollar-related findings. 

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AUDIT RESULTS 

Grant Program Planning and Execution 

The main purpose of the VOCA victim assistance grants is to enhance crime 

victim services. The WA DOC is the primary recipient of victim assistance grants at 

the state-level in Washington. The WA DOC distributes the majority of grant 

funding to organizations that provide direct services, such as: rape treatment 

centers, domestic violence shelters, child advocacy centers, and other communitybased victim coalitions and support organizations. As the state administering 

agency, the WA DOC has the discretion to select subrecipients from among eligible 

organizations, although the VOCA Guidelines require state administering agencies 

give priority to victims of sexual assault, domestic abuse, and child abuse. State 

administering agencies must also make funding available for previously 

underserved populations of violent crime victims.3 As long as a state administering 

agency allocates at least 10 percent of available funding to victim populations in 

each of these victim categories, it has the discretion in determining the amount of 

funds each subrecipient receives. 

As part of our audit, we assessed the WA DOC’s overall plan to allocate and 

award the victim assistance funding. We reviewed how the WA DOC planned to 

distribute its available victim assistance grant funding, made subaward selection 

decisions, and informed its subrecipients of necessary VOCA requirements. As 

discussed below, in our overall assessment of grant program planning and 

execution, we determined that the WA DOC appropriately identified and planned to 

meet additional victim service needs with its increased FYs 2015 – 2018 funding. 

Although we determined that the WA DOC took proper steps to announce its 

funding to subrecipients, it did not distribute grant funds appropriately because of 

its practice of combining VOCA and other fund sources when granting subawards, 

without always indicating the amount funded by VOCA awards. We identified that 

the WA DOC did not have a grants administration manual to guide its process of 

selecting subrecipients, and found that the WA DOC and a state-level pass-through 

agency did not communicate applicable VOCA requirements to its subrecipients, 

because of discrepancies in their subaward templates. 

3 The VOCA Guidelines state these underserved victims may include, but are not limited to, 

victims of federal crimes; survivors of homicide victims; or victims of assault, robbery, gang violence, 

hate and bias crimes, intoxicated drivers, bank robbery, economic exploitation and fraud, and elder 

abuse. The Guidelines also indicate that in defining underserved victim populations, states should also 

identify gaps in available services by victims' demographic characteristics. 

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Subaward Allocation Plan 

Prior to the significant increase in VOCA funding in FY 2015, the WA DOC 

allocated award funds in thirds based on existing state laws and a strategic plan 

for: (1) core services for sexual assault victims called Community Sexual Assault 

Programs (CSAPs), (2) emergency domestic violence shelters through interagency 

agreements with the DSHS, and (3) agencies serving all other crime victims called 

Crime Victim Service Centers (CVSCs).4 In 1979, the State of Washington passed 

laws that required the development of a state-wide plan to aid organizations that 

provide services to victims of sexual assault, and expand shelters for victims of 

domestic violence; while the 2005 Washington State Strategic Plan for Victim 

Services created the concept of the CVSCs.5 The WA DOC and the DSHS 

administered VOCA victim assistance grant funds, along with state funds, as 

formula-based annual funding to ensure a statewide network of service providers 

for all crime victims.6 

In response to the significant increase in CVF funding, the OVC’s FY 2015 

VOCA Victim Assistance Formula Solicitation required that state and territory 

applicants submit a subrecipient funding plan that detailed their efforts to identify 

additional victim service needs, as well as subaward strategies to spend the 

substantial increase in available VOCA funding. The WA DOC established a VOCA 

planning group to conduct a statewide planning process. The WA DOC convened 

several meetings with stakeholders to discuss the most appropriate ways of using 

the increased grant funds, which resulted in identifying under-funded victim 

services as well as underserved victim populations. 

In 2016, the WA DOC issued a VOCA State Plan for FYs 2015 through 2019 

based on needs identified by statewide stakeholders and included a spending 

allocation plan. Essentially, the state VOCA victim assistance plan intended to 

allocate approximately half of grant funds to support existing programs and the 

remainder to implement new initiatives that were identified with statewide 

stakeholders. The allocation plan included: 

• Investment in current services at 51 percent to maintain, enhance and 

expand existing programs in CSAPs, emergency domestic violence shelters, 

and CVSCs; 

• New initiatives at 45.5 percent that include specific services such as civil 

legal aid, human trafficking, sexual assault medical forensic services and 

other needs identified with stakeholders, such as child victims, culturally 

specific programs, and victim and witness assistance at county prosecutor’s 

office; and 

4 The WA DOC defines core services of the CSAPs as legal and medical assistance to ensure a 

24-hour, 7-day response to sexual assault victims. 

5 1979 State of Washington Victims of Sexual Assault Act and Shelters for Domestic Violence 

Act. 

6 The state of Washington’s fiscal year begins on July 1 and ends on the following June 30. 

See Appendix 3 for additional information of these programs. 

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• A reserve fund at 3.5 percent for training, language services, and 

unanticipated issues. 

In 2018, the WA DOC met with statewide stakeholders again and decided to 

extend the VOCA State Plan, utilizing the same allocation methodology by 

percentage until 2023. As such, we determined that the WA DOC adequately 

planned for the increase of VOCA victim assistance funds. 

Commingling of Subaward Funds 

The WA DOC used Interagency Agreements to subaward VOCA grant funds to 

two pass-through agencies, the DSHS and OCLA, who then subawarded again to 

subrecipients. We determined that four of the seven Interagency Agreements in 

our audit scope were funded by multiple federal VOCA awards that did not specify 

funding levels derived from each federal VOCA award. This resulted in both passthrough agencies not being able to properly account for each federal award 

separately, as required by the DOJ Grants Financial Guide. 

We reviewed the DSHS subawards within our scope for the five subrecipients 

that we judgmentally selected. We found that the DSHS funded some subawards 

with VOCA funds only, but the majority of the subawards were funded with a 

combination of VOCA funds, state funds, and the Federal Family Violence 

Prevention and Services Act grant funds awarded by the U.S. Department of Health 

and Human Services. Also, DSHS’ subawards that were solely VOCA-funded did not 

consistently specify funding amounts from each specific federal VOCA award. This 

resulted in DSHS subrecipients not being able to properly track grant activity by 

federal VOCA award numbers. 

For the other pass-through agency, OCLA, we found that its subawards to 

subrecipients were only funded by VOCA funds. However, because the WA DOC’s 

subawards to OCLA did not specify funding levels from a particular VOCA grant, 

OCLA’s subawards in turn were issued to subrecipients without specifically 

indicating the amount of funding from a particular federal VOCA award. This 

resulted in OCLA’s subrecipients not being able to properly track grant activity by 

federal VOCA award numbers. 

The WA DOC also issued subawards directly to subrecipients. We found that 

the WA DOC funded its subawards with either: (1) a single federal VOCA award; 

(2) multiple federal VOCA awards; (3) a single federal VOCA award and state 

funds; (4) multiple federal VOCA awards and state funds; or (5) a single federal 

VOCA award, state funds, and federal funds from the DOJ’s Office on Violence 

Against Women (OVW). 

From our judgmentally selected sample of 5 subrecipients, we reviewed a 

total of 65 subawards and determined 51 percent of VOCA funded subawards were 

commingled with non-VOCA funds. In the subaward contracts with multiple funding 

sources, the WA DOC did not always indicate the percentage funded by each fund 

source. We also did not find indications where the subrecipients inquired with the 

WA DOC, the DSHS, or OCLA for clarification on the breakdown of funding sources, 

6 
 

 

 

 

 

 

 

 

 

so that they could properly track grant activity by federal VOCA funding streams. 

The WA DOC maintained and provided us with copies of an internal accounting 

document, called the Commerce Contract Information Sheet (CIS), which showed 

its planned contract expenditure allocation for each subaward across the various 

funding sources. However, our testing determined that the WA DOC did not 

reimburse its subrecipients’ expenditures according to the allocation prescribed in 

the CIS. 

Due to the WA DOC and DSHS’s commingling of funding sources on 

subawards, and the subrecipients’ practice of capturing revenues and expenditures 

based on subaward contract numbers without separately accounting for the various 

funding sources, we conclude that the WA DOC and its subrecipients’ accounting of 

VOCA funds were not in accordance with DOJ Grants Financial Guide requirements. 

This practice prevented us from determining: (1) adherence to the allocation 

strategy in its VOCA State Plan, (2) compliance with the mandatory allocation 

requirements, and (3) accuracy of WA DOC’s federal financial and performance 

reporting. In addition, we did not select any expenses from subawards that were 

commingled with non-VOCA funding for expenditure testing. Instead, we focused 

our expenditure and match testing on subawards funded only with VOCA grants. 

Thus, we recommend that OJP ensure that the WA DOC reevaluates its subaward 

funding practices and develops procedures to ensure that all grant recipients can 

accurately and separately account for awarded funds within their accounting 

systems and financial records. 

Subaward Selection Process 

To assess how the WA DOC granted its subawards, we identified the steps it 

took to inform, evaluate, and select subrecipients for VOCA funding. Washington 

state law and WA DOC policies recommend that contracts for goods and services be 

conducted through a competitive solicitation process when practicable and 

applicable.7 The WA DOC did not have a grants administration manual, which we 

discuss in more detail later in the report. Consequently, we obtained an 

understanding of its subaward process through interviews with WA DOC officials 

and reviewing grant applications and instructions. 

We found that the WA DOC and its two pass-through agencies (the DSHS 

and OCLA) implemented the VOCA State Plan for 2015 to 2019 by administering 

these 14 grant opportunities as either formula (F) or competitive (C) programs.8 

• Existing services: 

- CSAP Core Services (F) 

- CSAP Specialized Services (F/C) 

7 Revised Code of Washington (R.C.W.) 39.26.120 (1) and WA DOC Policy (POL) 08.01.00. 

8 The WA DOC requires the CSAPs to meet with local stakeholders on a biennial basis to plan 

for specialized services for sexual assault victims, such as individual or group therapy, support groups, 

or medical social work. Based on meeting results, CSAPs could apply for funding either as formula or 

competitive grants. There are 29 federally recognized Native American Tribes in the State of 

Washington. The CVSC became a competitive grant program in 2019 during our audit. 

7 
 

 

 

 

 

 

 

- Emergency domestic violence shelters (F) 

- CVSC (C) 

- Enhancement and Expansion of current services (C) 

• New initiatives: 

- Sexual Assault Medical Forensic Exam Initiative (C) 

- Sexual Assaults: Marginalized Communities (C) 

- Civil Legal Aid (F) 

- County Prosecutor’s Office Victim Witness Assistance (F) 

- Child Advocacy Centers (F) 

- Native American Tribes (C) 

- Human Trafficking (C) 

- Unmet Needs (C); Cultural/Community Specific Programs (C) 

The WA DOC announced its formula and competitive grant programs on its 

website, from which applications and instructions could be downloaded. After the 

application deadline, WA DOC program managers reviewed applications for the 

formula programs while competitive request for proposals (RFP) went through an 

evaluation process by a panel of reviewers, composed of WA DOC employees and 

external participants. All reviewers had to certify their confidentiality and that they 

were free from conflicts of interest. At the completion of the review process, OCVA 

prepared a memorandum of obligation that summarized application results, the 

number and amount of subawards to be granted. The obligation memoranda 

required the approval and signature of a WA DOC Assistant Director before 

announcement of award decisions and the start of the protest procedures. Overall, 

we found no exceptions with the process that the WA DOC used to select 

subrecipients. 

We tried to quantify the subawards granted by the WA DOC, the DSHS, and 

OCLA from the VOCA victim assistance funds in our scope, as well as determine 

how closely the WA DOC adhered to the allocation strategy in its VOCA State Plan. 

However, due to the commingling of funding sources by the WA DOC, contrary to 

the requirements of the DOJ Grants Financial Guide, we were unable to determine a 

list of unduplicated subawards from one year to the next that directly corresponds 

to the annual federal victim assistance grants in our review. 

In order to assess the subawarding procedures, we judgmentally selected 

one formula program each from the WA DOC, the DSHS, and OCLA, as well as two 

competitive grant programs from the WA DOC for further review. 

Formula Funding Programs 

The WA DOC awards formula grants on an annual basis to CSAPs for the 

purpose of providing core services to victims of sexual assaults in their regions. 

These awards are a combination of VOCA and state funds of approximately the 

same amount. The DSHS awards formula grants on an annual basis for emergency 

domestic violence shelters based on interagency agreements that it enters with the 

8 
 

 

 

 

 

 

 

 

 

 

 

 

 

WA DOC on an annual basis. Finally, as a result of the VOCA State Plan for 2015-

2019, the WA DOC began entering into interagency agreements with OCLA to 

subaward 8.7 percent of the VOCA victim assistance funds for civil legal aid 

providers. OCLA awarded VOCA grant funds to civil legal aid programs that offered 

a unique legal expertise such as immigration and sexual assaults issues or had a 

strong relationship with local crime victim service providers. 9 

We determined that each year, the WA DOC, the DSHS and OCLA require 

subrecipients of these formula programs to complete a renewal process, which 

includes submitting budget data and information related to provision of program 

services. The three program offices complete a risk assessment process, which 

encompasses issues such as organizational changes, operating experience, and 

whether the subrecipients had been audited.10 We verified that the WA DOC, the 

DSHS and OCLA performed risk assessments on a judgmental sample of their state 

FY 2020 subrecipients for these three formula grant programs.11 

Competitive Method 

Of the 14 VOCA victim assistance program applications administered by the 

WA DOC after the increase in funding in FY 2015, over half were competitively 

awarded. We assessed the process used by the WA DOC in conducting competitive 

bidding by reviewing documentations from two judgmentally selected RFPs: 

(1) Sexual Assault Medical Forensic Examination VOCA Initiative of 2017; and 

(2) Unmet Victim Service Needs of 2018.12 Since WA DOC does not have a grants 

administration manual, we assessed its RFP process by reviewing grant application 

materials, certifications from reviewers, and a final memoranda signed by the WA 

DOC Assistant approving of the results. 

For the 2017 RFP that addressed inadequate and inconsistent access to 

sexual assault nurse examiners (SANE) across the state, the WA DOC provided a 

required certification of confidentiality and free of conflict of interest for all but one 

of the eight reviewers, and agreed to address its internal procedures on retaining 

reviewers’ certification. For the Unmet Needs RFP, the WA DOC provided 

certification from all 19 reviewers, as well as a new agreement that application 

materials be destroyed after review. We also verified that a WA DOC Assistant 

9 OCLA is an agency of the state’s judicial branch. The Washington State Administrative 

Office of the Courts specifically exempts civil legal aid contracts for client services from competitive 

procurement. 

10 During our audit, OCLA implemented a new policy to address two findings in the state of 

Washington FY 2018 Single Audit Report for not ensuring that its VOCA subrecipients had been 

assessed for risks and audited, when required. 

11 Because of the WA DOC’s practice of combining fund sources in its interagency agreements 

with pass-through agencies and VOCA subawards without including a breakdown of such sources in 

award documentation, we provide no assurance that the subrecipients could accurately determine 

their expenditures of federal resources in order to know whether they should be audited. 

12 The 2018 solicitation on unmet needs intended to address gaps of services based, in part, 

on geography and types of crime victims. 

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Director approved the final results of the 7 successful recipients for the SANE and 

22 for the Unmet Needs solicitations. No protests were filed. 

WA DOC officials informed us that each grant application is unique and 

creating a uniform procedure could hamper the process. Based on our review of 

the two competitive RFPs, we believe that the WA DOC should ensure that all RFPs 

follow a baseline of requirements, such as the composition of the review panel, 

retaining reviewers’ certifications, and the final memorandum submitted to the 

Assistant Director. Thus, we recommend that OJP ensure that the WA DOC develop 

a uniform policy for competitively bid grant applications, outlining baseline bid 

review procedures. 

Subaward Requirements 

State administering agencies must adequately communicate VOCA victim 

assistance requirements to their subrecipients. According to 2 C.F.R. § 200.331, 

pass-through entities must ensure that every subaward includes specific 

information so that award funds are used in accordance with the terms and 

conditions of the federal award. In addition, the WA DOC has a policy that requires 

the department to create and maintain a standard contract form, format, and 

content.13 We reviewed the WA DOC’s subaward solicitations and award packages 

to determine how the grantee communicated its subaward requirements and 

conveyed to potential applicants the VOCA-specific award limitations, applicant 

eligibility requirements, eligible program areas, restrictions on uses of funds, and 

reporting requirements. 

Prior to our audit, OVC conducted a site visit in September 2018 and found 

that the DSHS contract template was missing all required special conditions and the 

WA DOC contract template was missing six. In late 2018, OVC closed this finding 

after the WA DOC and the DSHS provided evidence that they revised their 

subaward contract templates. 

However, during our review, we still found inconsistent and inadequate 

subaward templets at both the WA DOC and the DSHS. Specifically, we reviewed 

two of the WA DOC’s subaward templates and three of the DSHS’ subaward 

templates to ensure that they included applicable award special conditions and a 

sample of the data elements found in 2 C.F.R. § 200.331.14 

We found that the DSHS contract templates contain the data elements that 

we selected for testing; however, the WA DOC contract templates was missing one. 

13 WA DOC POL 08.01.02, Standardizing Contract Templates (August 2015). 

14 We selected two OCVA subaward contract templates, one for Native American Tribe 

subrecipients and one for all other subrecipients. We selected three DSHS subaward contract 

templates, two for formula subawards and one for competitive subawards. The scope of our review 

included 4 of the 13 data elements specified in 2 C.F.R. § 200.331 (a) (1), as well as the 37 award 

special conditions in the FY 2017 VOCA victim assistance award, which was being administered by the 

WA DOC in 2019. 

10 
 

 

 

 

 

 

 

 

 

 

 

 

In addition, we found eight award special conditions that were either missing or 

incomplete in the subaward templates used by the WA DOC and the DSHS. 

Since there are subrecipients in the state of Washington that receive VOCA 

subawards from both the WA DOC and the DSHS, receiving subawards containing 

discrepant contract language could lead to confusion and noncompliance. The WA 

DOC informed us that each year it would communicate with the DSHS on the 

federal award requirements so that contract templates could be updated. The WA 

DOC also acknowledged discrepancies we found and has already begun to revise 

subaward templates. We recommend that OJP ensure that the WA DOC establishes 

procedures in drafting victim assistance program subaward templates by 

coordinating with pass-through agencies to ensure consistency, accuracy, and 

compliance with federal regulations and VOCA guidelines. 

Grants Administration Manual 

During our audit, we noted the WA DOC’s high number of grant programs, 

subawards, and the resulting administrative challenges. Specifically, as of 

December 2019, the WA DOC and its two pass-through agencies had awarded a 

total of 1,511 subawards from the 14 grant programs that fell within our scope. We 

found that despite the complexities of its programs, the WA DOC does not have a 

comprehensive grants administration manual to guide their execution. Instead, 

OCVA officials are provided separate office procedures that have not been 

integrated into a uniform guidance, and we had to supplement our review of 

OCVA’s procedures by using other sources such as grant application materials in 

order to gain a comprehensive view of its practice. As detailed in later sections of 

this report, we identified weaknesses in the programmatic and financial 

administration of grant funds. We identified at least one instance where an 

employee filed required reports incorrectly because she relied on an existing 

procedure as a new employee that proved faulty. Throughout this report, we 

identified areas of grant management that could be enhanced with developed 

procedures, that should be integrated into a comprehensive grant administration 

manual. We believe that a comprehensive grants administration manual would 

assist OCVA in ensuring that grants requirements are met and employees are 

appropriately trained. Thus, we recommend that OJP ensure that the WA DOC 

develop a comprehensive grants administration manual for OCVA to facilitate 

consistent administration of VOCA funds and compliance with the DOJ Grants 

Financial Guide. 

Program Requirements and Performance Reporting 

To determine whether the WA DOC distributed VOCA victim assistance 

program funds to enhance crime victim services, we reviewed the WA DOC 

distribution of grant funding via subawards among local direct service providers. 

We also reviewed WA DOC performance measures and performance documents that 

the WA DOC used to track goals and objectives. We further examined OVC 

solicitations and award documents and verified the WA DOC’s compliance with 

special conditions governing recipient award activity. 

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Based on our assessment in the areas of program requirements and 

performance reporting, we believe that the WA DOC complied with all but one of 

the tested special conditions. However, the WA DOC cannot definitively 

demonstrate that it has met the required allocation of grant funds to priority victim 

groups. 

Priority Areas Funding Requirement 

The VOCA Guidelines require that the WA DOC award a minimum of 

10 percent of the total grant funds to programs that serve victims in each of the 

four following categories: (1) child abuse, (2) domestic abuse, (3) sexual assault, 

and (4) previously underserved. The VOCA Guidelines give each state 

administering agency the latitude for determining the method for identifying 

"previously underserved" crime victims.15 The WA DOC reports the “previously 

underserved” based on the seven pre-defined crime types in the Performance 

Measurement Tool (PMT) module for that category.16 

We examined how the WA DOC allocated VOCA subawards to gauge whether 

it was on track to meet the program’s priority areas distribution requirements. As 

already stated, the WA DOC combined VOCA victim assistance grant funds with 

other sources in granting subawards to subrecipients and interagency agreements 

with pass-through agencies. In addition, the WA DOC does not have written 

procedures on tracking grant funds to ensure that it meets this distribution 

requirement. The WA DOC does track VOCA victim assistance funds for the 

distribution requirement by maintaining a spreadsheet of subaward funds awarded, 

including a breakdown of award funds by the priority categories. The WA DOC then 

updates this spreadsheet periodically as subrecipients expend grant funds and 

request reimbursements. However, due to the commingling of fund sources, we 

question the accuracy of distribution and expenditure data of this spreadsheet. As 

a result, we cannot definitively determine that the WA DOC has met the required 

distribution of grant funds for the priority categories. We recommend that OJP 

ensure that the WA DOC develop procedures to accurately capture its funding 

allocation to the four required VOCA priority categories to ensure compliance with 

VOCA requirements. 

Annual Performance Reports 

Each state administering agency must annually report to OVC on activity 

funded by any VOCA awards active during the federal fiscal year. OVC requires 

states to upload reports annually to its Grants Management System. As of 

FY 2016, the OVC also began requiring states to submit performance data through 

the web-based PMT. With this system, states may provide subrecipients direct 

access to report quarterly data for state review, although OVC still requires that if 

15 Methods for identifying “previously underserved” victims may include public hearings, 

needs assessments, task forces, and meetings with statewide victim services agencies. 

16 These seven types include driving under the influence crashes, survivors of homicide 

victims, assault, adults molested as children, elder abuse, robbery, and other violent crimes. 

12 
 

 

 

 

 

 

 

 

 

the subrecipient completes the performance measure data entry directly, the state 

must approve the data. 

For the victim assistance grants, the states must report the number of 

agencies funded, VOCA subawards, victims served, and victim services funded by 

these grants. Additionally, according to a special condition of the victim assistance 

grants, the state must collect, maintain, and provide to the OVC data that 

measures the performance and effectiveness of activities funded by the award. 

Due to the commingling of VOCA and non-VOCA funding sources by the WA DOC, 

performance data reported by subrecipients from such combined sources could not 

be definitively attributed to a specific fund. Consequently, we were unable to 

evaluate the accuracy of metrics compiled by the WA DOC. 

We verified that the WA DOC submitted annual performance reports to OVC 

from FYs 2015 through 2019. Because we could not verify the accuracy of the 

performance metrics, we reviewed two judgmentally selected narrative statements 

from the FY 2017 Annual Performance Report. For a statement on efforts of 

publicizing victim assistance funding, the WA DOC provided adequate evidence that 

it held a webinar to discuss funding opportunities from the VOCA victim assistance 

awards. For the other judgmentally selected statement on addressing VOCA 

priority categories, the WA DOC provided adequate evidence that it administered a 

grant program for accredited child advocacy centers. However, the WA DOC’s 

narrative statement incorrectly described it as a competitive program instead of a 

formula program, as stated in the memorandum of obligation signed by the WA 

DOC assistant director. We believe that implementing our recommendations on 

separate accounting of grant funds and including instructions on preparing 

performance data reports in the comprehensive grants administration manual 

would assist the WA DOC towards creating more reliable annual performance 

reports of its VOCA victim assistance awards. 

Compliance with Special Conditions 

The special conditions of a federal grant award establish specific 

requirements for grant recipients. In its grant application documents, the WA DOC 

certified it would comply with these special conditions. We reviewed the special 

conditions for the VOCA victim assistance program grants and identified special 

conditions that we deemed significant to grant performance which are not otherwise 

addressed in another section of this report. The two special conditions that we 

selected for further review required the recipient to: (1) report to OIG any potential 

fraud, waste, abuse, or misconduct involving or relating to the VOCA grant funds; 

and (2) submit a Subgrant Award Report (SAR) to OVC for each subrecipient of the 

VOCA victim assistance funds, within 90 days of awarding funds to subrecipients. 

For the special condition on reporting potential fraud, waste, abuse, or 

misconduct, we determined that internal controls exist for such reporting based on 

interviews we conducted or policies that we reviewed at the WA DOC, the DSHS, 

and OCLA. In addition, during our audit we noted that a subrecipient’s risk level 

was elevated to high in the spring of 2019, when the WA DOC learned that the 

executive director of the subrecipient was arrested for alleged fraudulent activities 

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and her employment terminated in late 2018. We determined that the WA DOC 

informed OIG of the alleged fraud perpetrated by the executive director within one 

month of becoming aware of the alleged fraud. In the Monitoring of Subrecipients 

section of this report, we discuss in further detail the additional monitoring 

conducted by the WA DOC on this subrecipient. 

The second special condition that we tested requires state grantees for each 

VOCA victim assistance grant to submit a SAR with basic information on each 

subaward to OVC. For the 4 VOCA victim assistance grants in our scope, we 

determined that the WA DOC and its 2 pass-through agencies had awarded 1,511 

subawards as of December 2019. However, we found that the WA DOC had 

submitted only 1,077 SARs. When we attempted to reconcile the number of SARs 

submitted with the total number of subawards granted, we found some reports that 

were: (1) missing or containing incorrectly formatted VOCA subaward numbers, 

(2) duplicates for the same subawards, and (3) submitted for multiple subawards. 

Ultimately, we were able to identify and reconcile 861 SARs submitted to the OVC, 

or a filing rate of approximately 57 percent. The employee responsible for 

preparing and submitting the SARs acknowledged that the WA DOC had a backlog 

of un-submitted reports and that she had relied on an existing procedure during the 

early part of her tenure, which had inaccurate instructions. The reliance on a 

procedure that proved inaccurate highlights the importance of our earlier discussion 

that a comprehensive grants administration manual is crucial in helping employees 

perform award-related functions. As such, we recommend that OJP coordinate with 

the WA DOC on the appropriate and reasonable submission of SARs for its 

previously awarded VOCA subawards; and implement procedures to ensure that 

SARs are submitted accurately and in a timely manner to OVC. 

Grant Financial Management 

According to the DOJ Grants Financial Guide, all grant recipients are required 

to establish and maintain adequate accounting systems and financial records in 

order to accurately account for awarded funds. The guide states that an adequate 

accounting system should be able to account for award funds separately.17 To 

assess the adequacy of the WA DOC’s financial management of the VOCA grants, 

we reviewed the process the WA DOC used to administer these funds by examining 

expenditures charged to the grants, subsequent drawdown requests, and resulting 

financial reports. To further evaluate the WA DOC’s financial management of the 

VOCA grants, we also reviewed the applicable Single Audit Reports and found no 

significant deficiencies or material weakness related to the WA DOC and its two 

pass-through agencies’ management of VOCA victim assistance awards for state 

FYs 2015 through 2017. However, Washington State’s FY 2018’s Single Audit 

Report found that one of the two pass-through agencies, OCLA, did not have 

17 The DOJ Grants Financial Guide requires recipients of federal funds to maintain accounting 

systems to ensure federal funds are not commingled with funds from other federal or private 

agencies. Recipients and subrecipients must account for each award separately and are prohibited 

from commingling funds on either a program-by-program or project-by-project basis. If the 

recipient’s or subrecipient’s accounting system does not make it possible to identify funds and 

expenditures with a particular program, a site visit or an audit of that program may result in those 

costs questioned or disallowed. 

14 
 

 

 

 

 

 

 

 

 

 

adequate internal controls to ensure that VOCA victim assistance subrecipients 

received required risk assessments and audits. As we discussed in the Subaward 

Selection Process section of this report, we found that OCLA has implemented a 

new policy on ensuring that its subrecipients have been assessed for risks and 

audited, as required. We also interviewed WA DOC, DSHS, and OCLA personnel 

who were responsible for financial aspects of the grants, reviewed OCVA written 

policies and procedures, inspected award documents, and reviewed financial 

records. 

We determined that the WA DOC’s drawdown of VOCA funds and submissions 

of Federal Financial Reports were supported by its financial systems. However, we 

found that WA DOC’s subrecipients could not account for VOCA funds separately as 

required by OJP due to the WA DOC’s practice of indistinguishably funding 

subawards with multiple funding sources. We also determined that the WA DOC did 

not have adequate controls to ensure its pass-through agencies and subrecipients 

were able to separately account for individual federal VOCA awards. 

Grant Expenditures 

State administering agency victim assistance expenses fall into two 

overarching categories: (1) reimbursements to subrecipients – which constitute the 

vast majority of total expenses, and (2) administrative expenses – which are 

allowed to total up to 5 percent of each award. To determine whether costs 

charged to the awards were allowable, supported, and properly allocated in 

compliance with award requirements, we tested a sample of transactions from each 

of these categories by reviewing accounting records and verifying support for select 

transactions. 

Subaward Expenditures 

As previously discussed, the DOJ Grants Financial Guide establishes that ”an 

adequate accounting system for a recipient must be able to accommodate a fund 

and account structure to separately track receipts, expenditures, assets, and 

liabilities for awards, programs, and subrecipients.” However, this did not appear 

to be the case for the WA DOC’s subrecipient expenses. We found that the WA 

DOC and its state-level pass-through agencies had commingled some VOCA funded 

subawards with non-VOCA funds without indicating the percentage of funds from 

each fund source. For these subawards, WA DOC subrecipients were unable to and 

did not separately account for expenditures in their accounting systems or on the 

Washington State Form A-19, Requests for Reimbursement, by funding type (VOCA 

versus non-VOCA). 

To evaluate the adequacy of financial controls over VOCA victim assistance 

grant expenditures, and subrecipients specifically, we limited our review to 

subawards that were funded through single or multi-year VOCA funds, and were not 

commingled with non-VOCA funds. We selected subrecipient transactions 

submitted for reimbursements from four subrecipients to determine whether the 

15 
 

 

 

 

 

 

 

 

 

 

 

payments were accurate, allowable, and in accordance with the VOCA Guidelines.18 

We judgmentally selected one Request for Reimbursement from four of the five 

subrecipients we visited, totaling $107,496. See Table 2 for a breakdown of our 

selected sample for each subrecipient. The transactions we reviewed included costs 

in the following categories: (1) personnel, (2) fringe benefits, (3) travel, and 

(4) operating costs. 

Table 2 

WA Subrecipient Expenses Tested and 

Dollars Questioned 

Subrecipient 

Subrecipient 

Expenditures 

Selected 

Unsupported 

Transactions Percentage 

1 $40,869 $37,153 91% 

2 51,287 33,054 64% 

3 5,121 0 0% 

5 10,219 0 0% 

Total $107,496 $70,207 65% 

Source: OIG Testing Results of Accounting Records 

For our testing, we reviewed and reconciled the supporting documentation 

provided to us in the form of allocation schedules, timesheets, invoices, pay stubs, 

bank statements, and other documentation. As a result of our testing, we 

questioned $70,207 in unsupported, or inadequately supported expenditures. In 

our review of the support provided by the subrecipients, we identified numerous 

inadequacies. For example, we found that Subrecipient No. 1 was allocating costs 

to its grant, but did not have a methodology that was supportable and logical. 

What’s more, Subrecipient No. 1 did not have adequate support, such as invoices, 

for several of the expenditures we tested. Likewise, its payroll and fringe expenses 

were not supported by timesheets, or any other documentation to support the 

amounts allocated to the VOCA award. We found that Subrecipient No. 2’s goods 

and services expenditures were supported, but its payroll and fringe expenditures 

lacked timesheets detailing VOCA hours worked to demonstrate its allocation 

methodology. We believe that the WA DOC and its pass-through agencies’ lack of 

financial monitoring may have contributed to the subrecipients’ inability to provide 

us with supporting documentation for our sampled expenditures, which we further 

discuss in the Financial Monitoring section of this report. Thus, we recommend that 

OJP remedy $70,207 in inadequately supported expenditures. 

18 Our expenditure testing did not include all five subrecipients we had judgmentally selected. 

Although Subrecipient No. 4’s subaward agreements awarded by the WA DOC were funded by both 

VOCA grant monies and state funds, we found our selected Subrecipient No. 4’s request for 

reimbursement was paid in its entirety with state funds. The WA DOC’s unreliable fund allocation 

methods and Subrecipient No. 4’s accounting of expenditure by subaward agreement numbers 

prevented us from being able to consistently trace transactions to accounting records. 

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Administrative Expenditures 

The state administering agency may retain up to 5 percent of each grant to 

pay for administering its crime victim assistance program and for training. According 

to the VOCA Final Rule, such costs must derive from efforts to expand, enhance, or 

improve how the agency administers the state crime victim assistance program and 

to support activities and costs that impact the delivery and quality of services to 

crime victims throughout the state. While federal grant-funded administrative costs 

generally must relate to a specific program, for VOCA assistance awards, the VOCA 

Final Rule states that funds for administration may be used to pay for costs directly 

associated with administering a state’s victim assistance program.19 

For the victim assistance grant program, we attempted to test the WA DOC’s 

compliance with the 5 percent limit on the administrative category of expenses. 

However, because the WA DOC entered into inter-agency agreements with the 

DSHS and OCLA, these two pass-through agencies are able to also charge the 

VOCA grants for administrative expenditures. Collectively, the WA DOC, the DSHS, 

and OCLA may not expend more than 5 percent of the VOCA grants on 

administrative expenditures. We first compared the WA DOC's administrative costs 

recorded in its financial records to the award amounts to determine if the WA DOC 

alone had exceeded the 5 percent limit. We found that the WA DOC alone had 

charged less than 5 percent for each grant, as shown in Table 3. 

Table 3 

WA DOC Administrative Expenditures 

Award Number Total 

Award 

Award 

Period 

End Date 

State 

Administrative 

Expenditures 

Administrative 

Percentage 

2015-VA-GX-0031 $42,761,431 09/30/18 $1,573,709 3.7% 

2016-VA-GX-0044 $48,821,061 09/30/19 $2,107,233 4.3% 

2017-VA-GX-0061 $41,060,865 09/30/20 $1,355,547 3.3% 

2018-V2-GX-0046 $74,702,737 09/30/21 0 0.0% 

Source: OIG Analysis of WA DOC Financial Records 

However, for a complete analysis and verification of whether the State of 

Washington complied with the 5 percent administrative cost limit, administrative 

costs among the WA DOC, the DSHS, and OCLA must be identified by each federal 

VOCA grant award. The lack of separate accounting of individual VOCA awards that 

we previously discussed created a situation where pass-through agencies’ 

administrative costs could not be attributed to individual VOCA grants. Thus, we 

were unable to determine whether the three agencies combined complied with the 

5 percent administrative cost limit requirement. 

19 OVC officials have indicated that the definition of a state’s “victim assistance program” may 

include both VOCA and non-VOCA activities supported by the state administering agency, as long as 

the activities relate to victim assistance. 

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In addition to testing the WA DOC’s compliance with the 5 percent 

administrative allowance, we also tested a sample of these administrative 

transactions. We judgmentally selected 12 transactions from the FYs 2015, 2016, 

and 2017 grants, totaling $137,060.20 The administrative transactions selected 

consisted of salaries and wages, travel, indirect costs, and rent. We analyzed the 

OCVA’s accounting records for the FYs 2015, 2016, and 2017 VOCA victim 

assistance grants for administrative expenditures. We reviewed and reconciled the 

supporting documentation provided to us in the form of allocation schedules, 

timesheets, payroll journals, purchase card logs, invoice vouchers, payment 

registers, bank statements, etc. We also analyzed the WA DOC’s Cost Allocation 

Manual and verified allocations were made in accordance with its stated procedures. 

Based on our testing, we determined that our sample of $137,060 in OCVA 

administrative costs were adequately supported. 

Drawdowns 

Award recipients should request funds based upon immediate disbursement 

or reimbursement needs and the grantee should time drawdown requests to ensure 

that the federal cash on hand is the minimum needed for reimbursements, or 

disbursements made immediately or within 10 days. To assess whether the 

WA DOC managed grant receipts in accordance with these federal requirements, we 

compared the total amount reimbursed to the total expenditures in the WA DOC’s 

accounting system and accompanying financial records. We also reviewed the WA 

DOC’s Federal Reimbursement Guidelines, and verified drawdowns initiated 

coincided with policies and procedures set forth within the guidance. Table 4 shows 

the total amount drawn down for each grant as of June 2020. 

Table 4 

Amount Drawn Down for Each Grant as of June 2020 

Award Number Total Award Award Period 

End Date 

Amount 

Drawn Down 

Amount 

Remaining 

2015-VA-GX-0031 $42,761,431 09/30/18 $42,761,431 $0 

2016-VA-GX-0044 48,821,061 09/30/19 48,821,061 0 

2017-VA-GX-0061 41,060,865 09/30/20 39,892,153 1,168,712 

2018-V2-GX-0046 74,702,737 09/30/21 26,038,876 48,663,861 

Total $207,346,094 $157,513,522 $49,832,572 

Source: OJP Information and OIG Analysis 

Note: Any differences are due to rounding. 

20 Due to the structuring of the Interagency Agreements, and resulting award tracking issues 

mentioned previously, a sample of administrative costs was not reviewed at the DSHS and OCLA. 

However, at the time of our fieldwork, OCVA had not charged administrative costs to the FY 2018 

grant. 

18 
 

 

 

 

 

 

 

 

 

 

 

Matching Requirement 

VOCA Guidelines require that subrecipients match 20 percent of the project 

cost. The purpose of this requirement is to increase the amount of resources 

available to VOCA projects, prompting subrecipients to obtain independent funding 

sources to help ensure future sustainability. Match contributions must come from 

non-federal sources and can be either cash or an in-kind match.21 VOCA Guidelines 

state that any deviation from this policy requires OVC approval. The state 

administering agency has primary responsibility for ensuring subrecipient 

compliance with the match requirements. 

The WA DOC subawards required that subrecipients provide non-federal 

match for the VOCA funds. Subaward contract agreements stipulate the match 

requirement as 20 percent or as a specific dollar amount. The agreements also 

stipulated that funds designated as match are restricted to the same uses as VOCA 

federal funds, match funds expended may exceed the minimum match funds 

required, and expenditures of match funds must be identified on subrecipients’ 

Requests for Reimbursements. We found that the WA DOC and its pass-through 

agencies allowed subrecipients to use state funds awarded on the same contract in 

order to satisfy the federal funds matching requirement. We also found that some 

subawards were exempt from the match requirement.22 

The WA DOC utilized its Contract Management System (CMS) to track total 

obligated and disbursed VOCA funds, as well as budgeted, obligated, reported, and 

outstanding match. The reports captured amounts of state funding that the WA 

DOC included within its subawards that were utilized as matching contributions, as 

well as the subrecipients’ reported match contributions. We reviewed the 

WA DOC’s CMS reports and determined that the WA DOC’s records indicate its 

subrecipients had met the 20 percent match requirement for the FYs 2015, 2016, 

and 2017 grants, and were on track to meet the requirement for the FY 2018 grant, 

whose project period had yet to conclude. However, due to the commingled nature 

of the WA DOC’s subawards, we could not confirm whether the WA DOC’s match 

records are accurate. 

To review the provision of matching funds at the subrecipient level, we 

selected and reviewed match amounts reported on three Requests for 

Reimbursements that were submitted to their respective awarding state agency. 

We reviewed $39,341 in matching costs, which consisted of volunteer hours, pro 

bono attorney clinic hours, and in-kind match. We verified match amounts to 

21 In-kind matches may include donations of expendable equipment, office supplies, workshop 

or classroom materials, workspace, or the value of time contributed by those providing integral 

services to the funded project. 

22 One of the five subrecipients that we selected for verification is a tribal government. The 

match requirement for subawards to Native American tribes and organizations located on reservations 

was 5 percent for the VOCA victim assistance grants, but this requirement was waived as of August 

2016. The WA DOC’s earliest subawards to this tribal government in our scope was funded with the 

WA DOC’s 2015 VOCA grant funds. However, we determined that these subawards were exempt from 

OJP’s matching requirement based on their 2017 award dates. Thus, this subrecipient was excluded 

from our judgmental sample review for matching. 

19 
 

 

 

 

 

 

 

 

 

 

supporting documentation in the form of volunteer timesheets, volunteer logs, and 

program intake forms. We also determined the reasonableness of volunteer labor 

rates claimed. Table 5 provides a summary of our testing. 

Table 5 

WA DOC Subrecipient Match Testing and Questioned Costs 

Subrecipient 

Subrecipient 

Match 

Selected for 

Testing 

Unsupported 

Transactions Percentage 

1 $ 3,172 $ 2,797 88% 

3 870 515 59% 

5 35,298 0 0% 

Total $ 39,341 $ 3,312 8.4% 

Source: OIG Testing Results of Accounting Records 

Note: Any differences are due to rounding. 

In its Request for Reimbursement for period January through March 2019, 

Subrecipient No. 1 had reported $55,994 of match in the form of pro bono attorney 

clinic hours from performing 163 individual clinic sessions. We judgmentally 

selected 8 clinic sessions or 10.3 clinic hours for review, which represented $3,172 

in match. The subrecipient provided us with client Program Intake Forms to 

support the clinic hours. In two instances, we found discrepancies between the 

clinic hours reported by the attorney and the hours supported by the 

documentation. We raised these concerns to Subrecipient No. 1, and they 

concurred that the discrepant amounts were not supportable. As a result of our 

testing, we determined 4.4 hours were supportable and we question the balance of 

5.9 clinic hours. Furthermore, Subrecipient No. 1 had reported a pro bono clinic 

rate of $308 per hour, which it informed us was based on an internal survey among 

its pro bono attorneys. However, Subrecipient No. 1 was unable to provide us 

evidence of its internal survey. Based on the U.S. Bureau of Labor Statistics Survey 

Data, we found that the 75th percentile hourly rate for an attorney in the same 

metropolitan area was $85.40 per hour. Due to Subrecipient No. 1 being unable to 

support its pro bono clinic rate, which was $222.60 above the going rate in the area 

for similar work, and the 5.9 hours of unsupportable clinic hours, we questioned 

$2,797 as unsupported match contributions reported. 

Subrecipient No. 3 had reported volunteer time and in-kind match on its 

Request for Reimbursement we judgmentally selected for testing. We reviewed and 

reconciled volunteer timesheets, and verified reasonableness of volunteer hourly 

rates reported. We found all volunteer hours to be supported and volunteer hourly 

rates to be reasonable. However, Subrecipient No. 3 had reported $515 of in-kind 

match and no documents were provided to support these costs. Thus, we question 

$515 of unsupported in-kind match related to Subrecipient No. 3’s reported match. 

Finally, we reviewed Subrecipient No. 5’s reported match in the form of 

volunteer time. We reviewed and reconciled volunteer timesheets and verified 

20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

reasonableness of volunteer hourly rates reported. We take no exception to the 

$35,298 of match contributions reported. 

We found unsupported costs for two of the three subrecipients we tested. 

The WA DOC and the pass-through agencies’ practice of not requiring source 

documentation for the reported match amounts and not performing financial 

reviews while onsite increase the risk of inaccurate match reporting, which we 

further discuss in the Financial Monitoring section of the report. Thus, we 

recommend that OJP remedy $3,312 of unsupported match contributions. 

Financial Reporting 

According to the DOJ Grants Financial Guide, recipients shall report the 

actual expenditures and unliquidated obligations incurred for the reporting period 

on each financial report, as well as cumulative expenditures. To determine whether 

the WA DOC’s OCVA submitted accurate Federal Financial Reports (FFRs), we 

compared the four most recent reports to OCVA’s accounting records for the 

FY 2015, 2016, 2017, and 2018 grants. We determined that quarterly and 

cumulative expenditures for the reports we reviewed were supported by OCVA’s 

accounting records for all four grants. However, as discussed in the Commingling 

of Subaward Funds section, we found that the WA DOC and its pass-through 

agencies have commingled VOCA victim assistance funds with state funds as well as 

other federal grants. Therefore, the amounts reported on the FFRs are based on 

commingled ledgers that may represent an inaccurate record of VOCA grant 

expenditures. Our previous recommendations that OJP ensures the WA DOC 

reevaluates its subaward funding practices and develop procedures within a 

comprehensive grants administration manual to ensure that all grant recipients can 

accurately and separately account for awarded funds within their accounting 

systems and financial records should ensure accurate FFRs. 

Monitoring of Subrecipients 

According to the DOJ Grants Financial Guide, the purpose of subrecipient 

monitoring is to ensure that subrecipients: (1) use grant funds for authorized 

purposes; (2) comply with the federal program and grant requirements, laws, and 

regulations; and (3) achieve subaward performance goals. As the primary grant 

recipient, the WA DOC must develop policies and procedures to monitor 

subrecipients. In addition, because of its interagency agreements with the DSHS 

and OCLA for granting subawards, the WA DOC needs to ensure that these passthrough entities also have an effective system of monitoring subawards. To assess 

the adequacy of the WA DOC monitoring of its VOCA subrecipients, we interviewed 

the WA DOC personnel, identified WA DOC monitoring procedures, and obtained 

records of interactions between the WA DOC, the DSHS, OCLA, and their 

subrecipients. We also conducted site visits at five judgmentally selected 

subrecipients, which included interviewing personnel, touring facilities, and 

reviewing accounting and performance records. We spoke with subrecipient 

officials to assess the level of support that they received from the WA DOC, the 

DSHS, or OCLA. Table 6 displays the five subrecipients in our verification scope by 

type of agency and VOCA subaward purposes. 

21 
 

 

 

 

Table 6 

Subrecipients Selected for Verification 

Subrecipient 

No. Agency Type 

VOCA Subaward Purposes 

CSAP 

Emergency 

Domestic 

Violence 

Shelter 

CVSC Other 

1 Non-profit No No No Legal Aid 

2 

Native 

American 

Tribe No No No 

Native American 

Tribe; 

Cultural-specific 

3 Non-Profit Yes Yes Yes N/A 

4 

County 

Government No No No 

Victim-Witness 

Assistance 

5 Non-Profit Yes Yes Yes N/A 

Source: OIG 

We determined that the WA DOC and the two pass-through agencies, the 

DSHS and OCLA, have a risk-based approach to the financial and programmatic 

monitoring of subrecipients. Furthermore, for the three existing programs, we 

found that the WA DOC’s OCVA has created service standards for the CVSCs and 

collaborated with a state coalition in creating a quadrennial accreditation program 

for the CSAPs. The DSHS staff members perform onsite visits to ensure compliance 

with state regulations of domestic violence shelters. 

We found evidence that the WA DOC and its two pass-through agencies have 

performed site monitoring of subrecipients, including one that had become a highrisk subrecipient during our audit. However, we found inadequate financial 

monitoring by the WA DOC, the DSHS, and OCLA. Furthermore, the WA DOC’s 

practice of granting interagency agreements to pass-through agencies and VOCA 

subawards to subrecipients from indistinguishable grant sources led to victim 

service programs supported by a combination of sources. Consequently, we were 

unable to assess the adequacy of performance monitoring of program results 

funded solely by VOCA victim assistance grant funds. 

In our overall assessment of the WA DOC and its pass-through agencies’ 

subrecipient monitoring, we found inadequacies in financial monitoring procedures, 

as well as program monitoring tools that could be further enhanced. 

Financial Monitoring 

The WA DOC and its pass-through agencies, the DSHS and OCLA, have 

formal monitoring policies and procedures that include conducting risk assessments 

that categorize its subrecipients into low, medium, and high-risk categories. See 

Table 7 for a summary of each entity’s level of monitoring based on risk 

assessments. 

22 
 

 

 

 

 

 

 

 

 

Table 7 

Financial Monitoring Activities on Subrecipients 

Low Medium High 

WA DOC • Desk monitoring only 

• Review of Requests for 

Reimbursements 

• Ensuring quarterly data 

reports are submitted 

• Review of supporting 

documentation for 

federal funding prerequisites identified in 

the program 

application 

• Low risk activities 

• Onsite visit from 

OCVA within the 

biennium 

• Consultation with 

other OCVA program 

staff is required if 

two or more 

programs scored in 

the medium or high 

risk range 

• All low risk activities 

• Onsite visit within 6 months of the 

risk assessment scoring 

• Review of back-up documentation for 

each Request for Reimbursement 

• Interviewing managers 

providing technical assistance, or 

consultation. 

DSHS • Monthly review of 

Requests for 

Reimbursements 

• Review of service data 

occurring once during 

the contract period 

• Review of single audit 

report 

• Compliance of the 

subrecipient’s selfassessment 

• Low risk activities 

• Review of service 

data twice during the 

contract period 

• Onsite visit occurring 

once during the 

contract period 

• Low and medium risk activities 

• Onsite monitoring visit staff training 

requirement checks 

• Review of source documentation and 

cost allocation data for Request for 

Reimbursement 

• Review of personnel files, job 

descriptions, grievance files review of 

policies, procedures, and related 

forms 

• Interviews with program staff and 

management 

OCLA • Data review 

• Onsite visits 

• Review of Requests for 

Reimbursements 

• Low risk activities 

• Onsite visit within 

12 months of the 

risk assessment 

scoring period 

• Low risk activities 

• Onsite visit within 6 months of the 

risk assessment scoring period 

Source: The WA DOC, the DSHS, and OCLA monitoring practices 

The WA DOC requires its subrecipients to submit reimbursement requests 

using the WA DOC’s CMS portal, which is used to administer and manage 

subawards. OCVA provides subrecipients access to specific subaward contracts so 

they may submit the Request for Reimbursement, along with supporting documents 

under each subaward contract. We found that subrecipients submit a Goods and 

Services worksheet that summarizes costs by cost categories, under each subaward 

contract. However, we determined that OCVA, the DSHS, and OCLA did not require 

subrecipients to submit supporting documentation in the form of source documents 

along with their reimbursement requests, nor did they conduct testing of 

expenditure samples to adequately mitigate the risk of unsupportable costs. The 

DSHS and OCLA only review the appended Goods and Services worksheets, verify 

calculations are correct, and determine whether itemized expenses within the 

Goods and Services worksheet are allowable and reasonable, then submit the 

requests to the fiscal staff for processing. Only DSHS’ policies for high risk 

23 
 

 

 

 

grantees elaborated on reviewing subrecipients’ source documentation for Requests 

for Reimbursements during an onsite visit. 

The WA DOC, the DSHS, and OCLA’s lack of financial monitoring raises the 

risk of unsupported Requests for Reimbursements being submitted by the 

subrecipients, and the risk of unallowable costs being reimbursed using VOCA 

funds. We are also concerned that their onsite visit procedures did not note the 

issue of their subrecipients’ commingled accounting records. Thus, we recommend 

that OJP ensure that the WA DOC and its pass-through agencies revise their 

financial monitoring policies and procedures to include the review of fiscal related 

matters to mitigate the risk of commingling and unsupported subrecipient Requests 

for Reimbursement. 

Performance Monitoring 

Due to the commingling of grant fund sources in the WA DOC’s interagency 

agreements with pass-through agencies and subawards to subrecipients, we 

conducted a limited assessment of performance monitoring by these state offices 

on the five VOCA subrecipients that we selected for verification. We interviewed 

subrecipients on their process of collecting performance data and reviewed a 

sample of case file documentation. Two of the five subrecipients in our sample 

received annual formula subawards as multi-program providers that served as the 

CSAP, emergency domestic violence shelters, and the CVSCs in their region. For 

these two subrecipients, we assessed whether the WA DOC and the DSHS have 

ensured that the subrecipients met the CSAP and the CVSC accreditation and 

service standards, as well as state regulations on domestic violence shelters. We 

found indications of underreported performance data that should be remedied. For 

the three existing programs, we found that the DSHS could enhance its onsite visit 

process and the WA DOC should include onsite monitoring plans for the CVSC 

service standards. 

Program Performance Data 

Current procedures of the WA DOC, the DSHS, and OCLA all require the 

review and evaluation of program performance data. To assess the adequacy of 

those procedures, we reviewed a sample of case files and interviewed officials at 

the five subrecipients on their procedures of maintaining performance data. 

Although we found evidence of direct services provided by these subrecipients in 

our review of case files, we could not attribute these services as solely funded by 

VOCA subawards due to the commingling of grant funds by the WA DOC. In our 

interview with subrecipient officials, we found underreported performance data from 

two subrecipients. For Subrecipient No. 1, whose VOCA subawards support the 

salary expenses of two employees, OCLA only reported the metrics from an 

attorney and not referral services provided by a legal advocate, based on the 

attorney’s providing more substantial work. OCLA agreed to correct this 

underreporting. For Subrecipient No. 4, whose VOCA subaward supports the salary 

expense of a victims and witnesses advocate, this individual stated that due to a 

high caseload and time constraints, she has entered her performance data of only 

new victims during a reporting quarter, but not those that she had continued to 

24 
 

 

 

 

 

 

 

 

provide assistance from prior quarters. As such, we believe that two of the five 

subrecipients in our scope have submitted incomplete data. Our previous 

recommendations that the WA DOC develop a comprehensive grants administration 

manual for OCVA to facilitate consistent administration of VOCA funds and 

compliance with the DOJ Grants Financial Guide should resolve these issues. 

State Regulations and Standards 

Subrecipients No. 3 and No. 5 in our sample are multi-program providers 

that serve as the CSAP, emergency domestic violence shelter, and the CVSC of 

their areas. These subrecipients have received commingled subawards from the WA 

DOC and the DSHS where subaward documents did not always provide a 

breakdown of the various sources. As a result, Subrecipients No. 3 and No. 5 have 

operated as multi-program providers from a combined source of funds. This 

practice by the WA DOC and the DSHS limited our attempt of assessing the 

performance monitoring of program operations supported only from VOCA grant 

funds. Consequently, our assessment was limited to our review of accreditation 

and service standards for the CSAP and the CVSCs, as well as the DSHS’s onsite 

monitoring practice of emergency domestic violence shelters. Our review identified 

two areas for improvement. 

The DSHS conducts onsite review of emergency domestic violence shelters 

every four years. These onsite reviews are supplemented by the annual subaward 

application process, where the DSHS performs a risk assessment and subrecipients 

must certify their compliance with state regulations.23 Our review of the checklist 

used by the DSHS in conducting site visits found that it does not include a state 

regulation that requires domestic violence shelters to have an annual safety 

inspections from the local fire department or fire marshal and correct any violations 

found.24 Instead, subrecipients certify their compliance with this requirement in the 

annual renewal application. Given that the DSHS conducts onsite visits every four 

years, requiring subrecipients to include this inspection report from the local fire 

department in the annual subaward renewal application could help the DSHS 

evaluate the shelters’ safety risk. As a result, we recommend that OJP ensure the 

DSHS update its annual renewal application process of emergency domestic 

violence shelters to require a copy of the most recent annual safety inspection 

report from the local fire department. 

During our assessment, we also noted that monitoring plans exist for the 

CSAP and emergency domestic violence shelters, but not the CVSCs. The WA DOC 

requires the CSAPs to maintain accreditation status, which is renewed every 4 years 

through an onsite review. Similarly, the DSHS procedures require onsite visits of 

the domestic violence shelters every 4 years. Although the WA DOC has created 

service standards for the CVSCs, no onsite monitoring mechanism exists to ensure 

23 Emergency domestic violence shelters must comply with regulations codified in the 

Washington State Administrative Codes (W.A.C.), Chapter 388-61A: Domestic Violence Victim 

Services and Prevention Efforts. 

24 Subrecipients No. 3 and No. 5 provided evidence of inspection from the local fire 

department to show compliance with W.A.C. 338-61A-1100 (8) during our audit. 

25 
 

 

 

that the CVSCs have complied with those standards. In light of OCVA’s recent 

decision of making the CVSC grant program a competitive process from a formula 

program, we believe that OCVA should perform onsite monitoring of CVSCs’ 

compliance with service standards, which could help OCVA evaluate the relative 

merits of CVSC grant applications on a competitive basis. Thus, we recommend 

that OJP ensure OCVA revise its CVSC service standards to include onsite 

monitoring plans. 

High-Risk Subrecipient 

We learned during our audit that a subrecipient’s risk level was elevated to 

“high” in March 2019, after the WA DOC learned of the alleged criminal behavior of 

its executive director, who was arrested in spring 2019. The alleged fraud involved 

VOCA victim assistance funds in our audit scope and was estimated to be under 

$10,000. According to the WA DOC, this subrecipient has been receiving VOCA 

grant funds for many years as a multi-program provider of the CSAP, the domestic 

violence shelter, and the CVSC. Besides informing OIG of the alleged fraud, the WA 

DOC and the DSHS conducted a coordinated site visit with this subrecipient in June 

2019, where they met with board members and the new executive director to 

discuss fiscal policies. The WA DOC followed up with additional reviews to ensure 

that oversight exists to prevent similar occurrences in the future. We believe that 

the WA DOC took appropriate steps in providing the necessary monitoring required 

for this high-risk subrecipient. 

26 
 

 

 

 

 

 

 

 

 

 

 

CONCLUSION AND RECOMMENDATIONS 

Overall, while we found that the WA DOC demonstrated adequate progress 

towards providing services to crime victims, our audit also identified instances 

where the WA DOC did not adhere to all the award requirements we tested. 

Specifically, we determined that the WA DOC did not have a comprehensive grants 

administration manual, which may have led to some of the issues we noted. The 

WA DOC did not accurately capture its funding allocation to the four priority 

categories to ensure compliance with VOCA requirements and did not submit 

accurate Subgrant Award Reports. 

Due to the WA DOC and a pass-through agency’s practice of funding 

subawards with VOCA and non-VOCA funds, we found that this caused 

subrecipients to commingle funds within their accounting systems and therefore be 

unable to differentiate VOCA expenditures from non-VOCA expenditures. Further, 

the subrecipients did not adequately support $70,207 in expenditures and $3,312 in 

match reported to satisfy VOCA guidelines. We also identified a weakness in the 

monitoring practice of a WA DOC’s pass-through agency that increased the safety 

risk of domestic violence shelter residents. Finally, the CVSCs are at risk of 

noncompliance with its service standards due to a lack of onsite monitoring plans. 

We provide 11 recommendations to OJP to address these deficiencies. 

We recommend that OJP: 

1. Ensure that the WA DOC reevaluates its subaward funding practices and 

develops procedures to ensure that all grant recipients can accurately and 

separately account for awarded funds within their accounting systems and 

financial records. 

2. Ensure that the WA DOC develop a uniform policy for competitively-bid grant 

applications, outlining baseline bid review procedures. 

3. Ensure that the WA DOC establishes procedures in drafting victim assistance 

program subaward templates by coordinating with pass-through agencies to 

ensure consistency, accuracy, and compliance with federal regulations and 

VOCA guidelines. 

4. Ensure that the WA DOC develop a comprehensive grants administration 

manual for OCVA to facilitate consistent administration of VOCA funds and 

compliance with the DOJ Grants Financial Guide. 

5. Ensure that the WA DOC develop procedures to accurately capture its 

funding allocation to the four required VOCA priority categories to ensure 

compliance with VOCA requirements. 

6. Coordinate with the WA DOC on the appropriate and reasonable submission 

of SARs for its previously awarded VOCA subawards; and implement 

procedures to ensure that SARs are submitted accurately and in a timely 

manner to OVC. 

27 
 

7. Remedy $70,207 in inadequately supported expenditures. 

8. Remedy $3,312 of unsupported match contributions. 

9. Ensure that the WA DOC and its pass-through agencies revise their financial 

monitoring policies and procedures to include the review of fiscal related 

matters to mitigate the risk of commingling and unsupported subrecipient 

Requests for Reimbursement. 

10. Ensure the DSHS update its annual renewal application process of emergency 

domestic violence shelters to require a copy of the most recent annual safety 

inspection report from the local fire department. 

11. Ensure OCVA revise its CVSC service standards to include onsite monitoring 

plans. 

28 
 

 

 

 

 

 

 

 

 

APPENDIX 1 

OBJECTIVE, SCOPE, AND METHODOLOGY 

Objective 

The objective of the audit was to evaluate how the State of Washington, 

Department of Commerce (WA DOC) designed and implemented its crime victim 

assistance program. To accomplish this objective, we assessed performance in the 

following areas of grant management: (1) grant program planning and execution, 

(2) program requirements and performance reporting, (3) grant financial 

management, and (4) monitoring of subrecipients. 

Scope and Methodology 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objective. We believe that 

the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objective. 

This was an audit of Victims of Crime Act (VOCA) victim assistance formula 

grants 2015-VA-GX-0031, 2016-VA-GX-0044, 2017-VA-GX-0061, and 

2018-V2-GX-0046 from the Crime Victims Fund awarded to the WA DOC. The 

Office of Justice Programs (OJP), Office for Victims of Crime awarded these grants 

totaling $207,346,094 to the WA DOC, which serves as the state administering 

agency. Our audit concentrated on, but was not limited to, the period of 

September 2015, the project start date for VOCA assistance grant number 2015-

VA-GX-0031, through January 2020. As of June 2020, the WA DOC had drawn 

down a total of $157,513,522 from the four audited grants. 

To accomplish our objective, we tested compliance with what we consider to 

be the most important conditions of the WA DOC’s activities related to the audited 

grants. We performed sample-based audit testing for grant expenditures including 

payroll and fringe benefit charges, administrative expenses, financial reports, 

performance reports, etc. In this effort, we employed a judgmental sampling 

design to obtain broad exposure to numerous facets of the grants reviewed. This 

non-statistical sample design did not allow projection of the test results to the 

universe from which the samples were selected. The authorizing VOCA legislation, 

the VOCA victim assistance program guidelines, the Department of Justice (DOJ) 

Grants Financial Guide, and the award documents contain the primary criteria we 

applied during the audit. 

During our audit, we obtained information from OJP’s Grants Management 

System and Performance Measurement Tool, as well as the WA DOC accounting 

system specific to the management of DOJ funds during the audit period. We did 

not test the reliability of those systems as a whole; therefore, any findings 

29 
 

 

identified involving information from those systems was verified with documents 

from other sources. 

While our audit did not assess the WA DOC’s overall system of internal 

controls, we did review the internal controls of the WA DOC’s financial management 

system specific to the management of funds for each VOCA grant within our review. 

To determine whether the WA DOC adequately managed the VOCA funds we 

audited, we conducted interviews with the State of Washington financial staff, 

examined policies and procedures, and reviewed grant documentation and financial 

records. We also developed an understanding of the WA DOC’s financial 

management system and its policies and procedures to assess its risk of noncompliance with laws, regulations, guidelines, and terms and conditions of the 

grants. 

30 
 

 

 

 

 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

Description Amount Page 

Questioned Costs: 

Unsupported Subrecipient Expenditures 

Unsupported Match Costs 

Total Unsupported Costs 

Total Questioned Costs25 

$70,207 

3,312 

$73,519 

$73,519 

16 

20 

25 Questioned Costs are expenditures that do not comply with legal, regulatory, or 

contractual requirements; are not supported by adequate documentation at the time of the audit; or 

are unnecessary or unreasonable. Questioned costs may be remedied by offset, waiver, recovery of 

funds, the provision of supporting documentation, or contract ratification, where appropriate. 

31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 3 

WASHINGTON STATE CRIME VICTIM SERVICE PROVIDERS 

The statewide development of crime victim services in Washington could be 

traced to the 1979 Victims of Sexual Assault Act and a similar law that same year 

on shelters for victims of domestic violence. The 2005 Washington State Strategic 

Plan for Victim Services completed that network by creating the concept of the 

Crime Victim Service Center (CVSC) for all other crimes. Providers of these three 

programs receive VOCA subawards on an annual basis. The 2005 Strategic Plan 

also divided the state into 13 geographic regions by county for planning and 

allocating resources, which remained in practice in our audit scope until state 

FY 2020.26 Table 8 displays the number of crime victim service providers as of 

state FY 2019 by type and region, including agencies serving two or all three 

programs. The regional map follows, in Figure 2. 

Table 8 

Washington State FY 2019 Crime Victim Service Providers 

Region 

No. 

Community 

Sexual Assault 

Program (CS) 

Emergency 

Domestic 

Violence 

Shelter (DV) 

Crime Victim 

Service 

Center (CV) 

Multi-Program Providers 

CS 

DV 

CV 

CS 

DV 

CS 

CV 

DV 

CV 

1 3 5 7 0 1 2 0 

2 1 1 5 0 0 0 0 

3 1 1 2 0 0 1 0 

4 2 2 2 0 1 1 0 

5 3 3 3 1 2 0 0 

6 2 2 2 2 0 0 0 

7 3 3 3 0 2 0 1 

8 3 3 3 2 1 0 0 

9 2 2 3 2 0 0 0 

10 4 5 2 1 2 1 0 

11 5 5 4 1 3 0 0 

12 3 3 3 0 3 0 0 

13 4 4 3 2 1 1 0 

Total 36 39 42 11 16 6 1 

Source: OIG analysis of OCVA and the DSHS data 

26 In state FY 2020, the WA DOC did away with the regional concept and changed the CVSC 

to a competitive grant program, rather than a formula-based allocation on factors such as population. 

The community sexual assault programs and emergency domestic violence shelters would remain 

formula-based programs. 

32 
A OR 

Wll'\ IC M 

CLARK 

12 

SK/\GI \ 

4 

SNOHO ISH 

CHE [\ 

ITTI AS 

10 

YAKl '1A 

5 AMAMA,...JIL__ __ 

L 

0 

-g., 

l 

A OGA 

l{f y 

6 

STEVENS 

- ' s LINCOLN 3 

8 

GRAT 

ADAMS 

FRA\J Ll\J 

1 

SPOl(ANE 

WHITMAN 

GARFIELD 

CO MBIA 

BEf\ TOI'. 1NA LA ~1 M L A :\SO I 

Figure 2 

Washington State CVSC Regions 

Source: The WA DOC 

33 
APPENDIX 4

STATE OF WASHINGTON DEPARTMENT OF COMMERCE 

RESPONSE TO THE DRAFT AUDIT REPORT 

34 

OF WASHINGTON 

DEPARTMENT OF COMMERCE 

1011 Plum street SE • PO Box 42525 • Olympia, Washington 98504-2525 • (360) 725-4000 

www.commerce.wa.gov 

August 6, 2020 

DavidJ. Gaschke 

Regional Audit Manager 

San Francisco Regional Audit Office 

Office of the Inspector General 

U.S. Department of Justice 

90 7th Street, Suite 3-1 00 

San Francisco, CA 94103 

Dear David Gaschke: 

The Washington State Department of Commerce (Commerce) is thankful for the opportunity to provide a 

written response to the draft Audit Report of the Office of Justice Programs ( OJP), Victim Assistance 

Grants awarded to Commerce. This letter serves as our official response to the audit recommendations 

made by the Office of the Inspector General to the Office of Justice Programs, dated July 21, 2020, that 

are listed on pages 28-29 of the audit report. 

Recommendation 1: Ensure that Commerce reevaluates its sub-award funding practices and develops 

procedures to ensure that all grant recipients can accurately and separately account for awarded funds 

within their accounting systems and financial records. 

• Response: Commerce concurs with this recommendation and will work with OJP to evaluate our 

sub-award funding practices and procedures to ensure all grant recipients can accurately and 

separately account for awarded funds within their accounting systems and financial records. 

Recommendation 2: Ensure that Commerce develop a uniform policy for competitively-bid grant 

applications, outlining baseline bid review procedures. 

• Response: Commerce concurs with this recommendation and has begun work on a uniform 

procedure for all Victim of Crime Act (VOCA) funded competitively-bid procurements. 

Recommendation 3: Ensure that Commerce establishes procedures in drafting victim assistance program 

sub-award templates by coordinating with pass-tlu·ough agencies to ensure consistency, accuracy, and 

compliance with federal regulations and VOCA guidelines. 

• Response: Commerce concurs with this recommendation and has begun work on written 

procedures to ensure sub-award contract template consistency, accuracy, and compliance with 

federal regulations and VOCA guidelines. 
Gaschke, Regional Audit Manager 

Response to Recommendations 

August 6, 2020 

Page2 

Recommendation 4: Ensure that Commerce develop a comprehensive grants administration manual for 

the Office of rime Victims Advocacy (0 V ) to facilitate consistent administration ofO funds and 

compliance with the Department ofJustice (DOJ) Grants Financial Guide. 

• Response: Commerce concurs with this recommendation and OCVA staff have begun work on a 

comprehensive grants administration manual. 

Recommendation 5: Ensure that ommerce develop procedures to accurately capture its funding 

allocation to the four required VO A priority categories to ensure compliance with VOCA requirements. 

• Response: Commerce concurs with this reco,nme;-ndation and OCV A staff have begun work on a 

written procedure outlining how the VOCA priority categories are tracked to ensure compliance. 

Recommendation 6: Coordinate with Commerce on the appropriate and reasonable submission of Subgrant Award Reports (SARs) for its previously awarded VOCA sub awards; and implement procedures to 

ensure that SARs are submitted accurately and in a timely manner to Office for Victims of Crime. 

• Response: Commerce concurs with this recommendation and is cmTently assessing staff 

resources to allocate additional staff to this work. 

Recommendation 7: Remedy $70,207 in inadequately supported expenditures. 

• Response: Commerce concurs with this recommendation and will work with Office of Justice 

Programs (OJP) to resolve this issue. 

Recommendation 8: Remedy $3,312 ofunsuppo,ted match contributions. 

• Response: Commerce concurs with this recommendation and will work with OJP to resolve this 

issue. 

Re1.,-ommendation 9: Ensure that Commerce and its pass-through agencies revise their financial 

monitoring policies and procedures to include the review of fiscal related matters to mitigate the risk of 

commingling and unsuppo,ted sub-recipient Requests for Reimbursement. 

• Response: Commerce concurs with this recommendation. As of July 1, 2020 the VOCA 

Assistance program implemented revised fiscal monitoring procedures to include review of fiscal 

related matters. Commerce will review tliese procedures with OJP. 

Recommendation 10: Ensure tl1e Department of Social and Health Services (DSHS) update its annual 

renewal application process of emergency domestic violence shelters to require a copy oftl1e most recent 

allllual safety inspection report from the local fire department. 

• Response: Commerce concurs with this recommendation and DSHS has added the requirement 

lo include a copy of the annual safety inspection report to their application process. 

Recommendation 11: Ensure OCV A revise its Crime Victims Se,vice Centers (CVSC) se,vice standards 

to include onsite monitoring plans. 

35 
Gaschke, Regional Audit Manager 

Response to Recommendations 

August 6, 2020 

Page3 

• Response: Commerce concurs with this recommendation and will add the onsite monitoring plan 

procedures to the CVSC seivice standards document 

Commerce appreciates the opportunity to respond to the draft audit repo1t, as well as the opportunity to 

improve its serv ices to fund and administer projects serving c1ime victims in Washington state. 

Sincerely, 

Lisa Brown 

Director 

Washington State Depa1tment of Commerce 

cc: Diane Klontz 

ssistant Director 

Community Se1vices and Housing Division 

Washington State Department of ommerce 

Richard Torrance 

Managing Director 

Office of Crime Victims Advocacy 

Washington State Department of ommerce 

36 
 

APPENDIX 5 

WASHINGTON STATE OFFICE OF CIVIL LEGAL AID RESPONSE 

TO THE DRAFT AUDIT REPORT27 

State Office of Civil Legal Aid 

1206 Quince St. SE James A. Bamberger, Director 

Olympia, WA 98504 jim.bamberger@oda.wa.gav 

MS41183 

360-704-4135 

To: David Gashke (DOJ OIG Audit Team) 

From: Jim Bamberger, Director 

CC: Nicky Gleason, OCVA 

Re: DOJ OIG Draft Audit Report 

Date: August 19, 2020 rev. 9-4-2-20 

We have reviewed the Draft Audit Report forwarded to the Department of Commerce on July 21 , 

2020. Before commenting on the issues raised about the O LA subrecipient tested (Subrecipient 

No. 1), I'd like to lake a moment to thank you all for the constructive and thoughtful approach to 

the engagement. We found each member of the team to be courteous, respectful, and at all times 

professional. This has been a long process, disrupted and extended in part by the COVJD-19 

emergency. Never1heless, the resulting report offers a fair assessment of the Office of Civil 

Legal Aid's role in administering and overseeing the VOCA funding made available for civil 

legal aid through our interagency agreement with Commerce/OCVA 

In this memo we briefly address the following three issues relating to the expenditure of VOCA 

funding by Subrecipient o.: 

l . Subrecipient o. l could not substantiate the personnel expenses associated with staff 

assigned to the VOCA project. 

2. Subrecipient No. 1 could not or did not provide back-up documentation or written 

procedures to support its allocation of non-personnel costs to the VOCA subgrant. 

3. Subrecipient o. l did not properly docun,ent the methodology used to calculate match. 

The Draft Report questions the following costs: $35,125 representing three months personnel 

expenses associated with the VOCA-funded Project Safety attorney and navigator, and $3,312 in 

clain,ed match contributions. Working papers comparing payroll records produced to the OIG 

auditors were compared with the A-19 invoice submitted to and approved by OCLA. The OIG 

identified a $4,211 difference. 1 For the reasons outlined in the subrecipient's March 17, 2020 e1 We note U1at in Attachment I to a July 17, 2020 explanatory e-mail. U,e 010 identified a$5,743 discrepancy 

between what was invoiced 10 OCLA and the bacl..11p docwnentation provided by Subrecipienl No. I supporting 

payroll records for lhat period. SubrecipieIII No. I explained the apparenL discrejXlllcy in an e-mail dated March 17, 

2020 (10:50 am.). The reconciled A-19 sent in 11,at s 1me July 17, 2020 e-mail shows a di crepancy of$4,2 I I. We 

do not undentand from where Uic $5,743 figure was derived. 

Washington Sin Otrtce of Civd Legal Aid 

UndeNltfting Justice • Ensuring Accountabilq 

27 Attachments referenced in this response were not included in the final report. 

37 
and suppo1ting documents, OCLA believes the OIG's approach to reconciliation is inco1Tect 

and that there hould be no questioned expense here. 

1. Questioned Cost o. 1: Personnel Expenses 

ll1e OIG questioned the allocation of 100% of personnel expenses for two VOCA-grant funded 

staff positions - an attorney who is dedicated entirely to crime victim work for domestic violence 

victims and a navigator who works exclusively on Project Safety. Project Safety is a partnership 

between the King County Prosecuting Attorney's Office (KCPAO) and three civil legal aid 

programs. It i. designed to provide early identification of VOCA eligible domestic violence 

crime victims in need of civil legal representation and refeJTal of these victims to pruticipating 

civil legal aid programs. Subrecipient No. 1 plays a unique connecting role in hosting the Project 

Safety Navigators - individuals ( one VOCA-funded) who work in paitnership with KCP A O's 

domestic violence victim advocates to identify and facilitate victim refeJTals from the criminal 

justice side to the VOCA-funded civil justice side. 111e allomey and na igalor charged to the 

VOCA grant were hired ru1d assigned exclusively (100% FTE) to engage in VOCA-funded work. 

l11ey do not provide services or engage in organizational activities unrelated their VOCA-funded 

crime victim work. While Subrecipient No. I has not incorporated the best practice of executing 

a semi-amrnal certification, all personnel related documentation confirms that these two 

employees are 100% dedicated to VOCA work. Cons quently, OCLA di agrees with the OIG's 

questioning of personnel costs associated for these two staff persons. 2 

Further, as these staff persons were funded 100% from the VOC grant source, the payroll 

documentation would fall under the Unifonn Guidance Section 200.430 - Personal Services. 

111 is allows that certifications are allowable, but no longer required. 

As outlined in the preamble: 

Section 200.430 Compensation- Personal Services strengthens the requirements 

for non-Federal entiti s to maintain high standards for internal controls over 

salaries and wages while allowing for additional .flexibility in how non-Federal 

entities implement processes to meet those standards. In addition, it provides for 

F deral agencies to approv alternative methods of accounting fo r salaries and 

wages based on achievement ofperfom1ance outcomes, including in approved 

instances where funding from multiple programs is blended to more efficiently 

achieve a combined outcome. 

111e prerunble further states that: 

While many non-Federal entities may still find that existing procedures in place 

such as personal activity reports and similar docum ntation are the best method 

for them to meet the internal control requirements, this final guidance does not 

' As noted above, OCLA disagrees that there is a di. crepancy between actual and invoiced personnel expenses for 

the period in question, as OIG failed to follow up on the reconciliation trail provided in the March 17"' e-mail from 

Subrcdpicnt No. I. 

38 
require them. The focus in this final guidance on overall internal 

controls mitigate the risk th at a non-Federal entity or their auditor will focus 

solely on prescribed procedures such as reports, ce1tifications, or ce1tification 

time periods which alone may be ineffecti ve in as ' uring full accountability. 

(Emphasis added). 

As the two salaried personnel were working and their hours were documented through the 

payroll system, the costs were incurred properly. It appears this is more of an intemal control 

issue of documentation rather than a questioned cost. A questioned cost is an unallowable cost. 

As the payroll was allowed and the two staff people were working on the VOCA project, these 

should not be characteri zed as unallowabl e costs. 

Corrective Action: Subrecipient o. 1 will improve internal control by instin1ting a semiannual certification protocol pursuant to which staff dedicated exclusively to OCA-funded 

work will document the same. Allocation of personnel expenses for staff (if any) engaged in a 

mix of VOCA and non-VOCA funded work will be documented by timesheets backed up by 

contemporaneous timekeeping records. 

2. Questioned Cost o. 2: on-Personnel Expenses 

OIG was unable to confmn the approach and guidelines us d by Subrecipient o. 1 to allocat 

certain non-personnel expenses. As outlined in Attachment 1 to OIG's e-mail of July 17, 2020, 

Subrecipient No. 1 did not provide OIG with documentation outlining Subrecipient o. l 's cost 

allocation methodology. The OIG therefore questioned a number of the costs assign d to the 

Goods and Services line it m. CLA does not challenge this finding or the costs that have been 

questioned. 

Corrective Action: OCLA has engaged an independent accounting finn to undertake a review 

ofSubrecipient o. l 's accounting, cost all ocation, timekeeping and other practi ces related to the 

VOCA subgrant under the ICP reporting standards for Agreed pon Procedures. TI,is :finn is 

an approved vendor under the \\I A Office of Procurement for personal services. TI1e film will 

provide Subrecipi ent o. I's fiscal and administrati ve t am with technical suppo1t and guidanc 

including, but not limited to, properly documenting and implementing cost allocation 

methodologies and practices that ensure and substantiate proper allocation along with suppo1ting 

documentati on of all personnel and 11 011-persom,el expenses charged to the VOCA subgrant. 

3. Questioned Cost o. 3: atch 

l11e 010 notes that Subrecipient No. I values the contributions of private attorney volunteers at a 

market rate of $308/hr. This reflects the av rag billing rate charged by Subrecipient o. 1 

volunteers for similar legal services to their paying clients. nfortunately, the survey itself was 

conducted on an early version of Survey Monkey, and the data generated through that survey 

was no longer availabl e to Subrecipient o. l at the Lime of the engagement, and tlm~ not 

available to the 010 team. 

39 
and the O IG do not disagree that market rate is an appropriate yardstick for detennining 

the value of volunteer attorney services as match. Tiie IG's concern is that Subrecipient No. 

lcould not suppott the $308/hr. figure with any backup documentation. Lacking backup 

documentati on, OIG imputed a rate of 85/hr. which is derived from Bureau of Labor Statistics 

survey data for the 75111 percentile hourly rate for attorney. in that market. 

111e OIG's imputed valuation approach compares apples to oranges. The BLS survey data is not 

an indication of the average market value of services (the price charged to paying clients for 

simil ar work), but the av rage salary in the market. During a .July 17, 2020 conference call, OIG 

acknowledged that the BLS numbers are not the best indicator of the value of services, but tl1at 

they had to use it for the lack of any other number. Using the BLS number and questioning 

certain match entri es that were inappropriate, 010 questioned $2,797 in claimed match for the 

period in question. 

Even accepting the BLS approach and removing the 5.9 challenged hours, a year-long revi ew of 

Subrecipient No. l 's match contribution demonstrates that they produced well in excess of the 

required match during FY 2019 just on volunteer hours alone. Attachment 1 shows claimed 

match at $308/hr. for each quarter and the total. TI1e total number of hours of attorney services 

documented was 577.5. At $308/hr., match claimed was $177,870. Removing 5.9 questioned 

hours, the total match hours for FY 2019 is 571.6. At $85/hr., the total match value is $48,586. 

TI1is exceeds the required match of $44,400 by $4,186. OCLA asks the OIG to reconsider these 

questioned costs. 

Additionally, the match criteria set forth in the final VOCA Guidelines allow for both pro-bono 

attorney costs and cash from oth r sources. Subrecipient o. 1 regularly invests substantial cash 

from other sources to the crim victims project which, in addition to the allowable volunteer 

attorney match (even at BLS value), more than meet the match po1tion for both the period in 

qu stion and th entire fiscal year. lf n eded, OC proposes that the qu stioned cost (match 

shortfall) be covered with !he allowable cash contributions from other sources. 

Corrective Action: OCLA will require Subrecipient No. 1 to conduct a biennial market survey 

of its volunteer attorneys to establish a meaningful and objectively supportable match value for 

volunt r attorney servic s provided to clients in VOC -eligible cas s. 1f needed, Subrecipi nt 

o. l will also submit cash from other sources as part of the allowable match for the audited 

period in question. 

40 
APPENDIX 6 

OFFICE OF JUSTICE PROGRAMS RESPONSE TO 

THE DRAFT AUDIT REPORT 

41 

.S. Department of Justice 

Office of J11stice Programs 

Office of Audit, Assessment, and Management 

IJ'a.shing1011, D.C. J0S3 1 

August 19, 2020 

MEMORANDU!vl TO: David J. Gaschke 

Regional udit Manager 

San Francisco Regional Audit Office 

Office of the Inspector General 

FRO Ralph E. Ma11in 

Director ~~ 

S BJECT: Re pon e to the Draft Audit Repo1t, A11dit of the Office of Justice 

Programs, Victim Assistance rants Awarded to the tate of 

Washington Departinent of Commerce, Olympia, Washington 

111is memorandum is in reference to your correspondence, dated July 21 , 2020, transmitting the 

above-referenced draft audi1 report for the State of Washington Department of Commerce 

(W DOC). We consider the subject report resolved and request written acceptance of this 

action from your office. 

TI1e draft report contains 11 recommendations and $73,519 in questioned costs. Ibe following is 

Office of Ju:tice Programs' (OJP) analysis of the draft audit report recommendation .. For ease 

of review, the recommendations are restated in bold and are followed by our response. 

J. We recommend that O,n, ensure that the WA DO 1·ce\'aluates its uhaward 

funding practices and develops procedures to ensure that all grant recipients c,m 

accw·at.ely amt separately account for awarded fw1ds within their accow1ting 

systems and fmancial records. 

O.JP agrees with this recommendation. We will coordinate with W DOC to obtain a 

copy ofw1itten policies and procedures, developed and implemented, to ensure that all 

subrecipients accurately and separately account for Federal award funds within their 

accounting systems and financial records. 
We recommend that OJP ensure that the WA DOC develop a uniform policy for 

competitively-bid grant applications, outlining baseline bid review procedures. 

JP agrees with this recommendation. We will coordinate with WA DOC to 

obtain a copy of written policies and procedur.,s, developed and implemented, to 

ensure they include baseline requirements for reviewing competitively-bid grant 

appli cations. 

3. We reconunend that OJP ensure that the WA DOC establishes procedures in 

dratling victim assistance program suhaward templates hy coordinating with 

pass-th1·ough agencies to ensm·e consist.ency, accuracy, and compliance with Federal 

regulations and VOCA guidelines. 

O.JP agrees with this recommendation. We will coordinate with WA DOC to obta.in a 

copy of written policies and procedures, developed and implemented, for drafting victim 

assistance progran1 award templates, by coordinating with pass-through agencies to 

ensure consistency, accuracy, and compli ance with Federal regulati ons and ictims of 

Crime Act (VOCA) guidelines. 

4. We reconunend that OJP ensure that the WA DOC develop a comprehensive grants 

administration manual for OCV A to facilitate consistent administration of VOCA 

funds and compliance with the DOJ Grants Financial Guide. 

OJP agrees with this recommendation. We will coordinate with WA DOC to obtain a 

copy of written policies and procedures, developed and implemented, for its Office of 

Crime Victims Advocacy (OCV A), to ensure consistent administration of VOCA fonds 

and compliance with the Depaitment of Justice (DOJ) Grants Financial Guide. 

5. We reconunend that OJP ensure that. the WA DOC develop procedures to 

accurat.ely capture its funding aUocation to the four required VOCA priority 

categories to ensure compliance with VOCA requirements. 

OJP agrees with this recommendation. We will coordinate with WA DOC to obtain a 

copy of written policies and procedures, developed and implemented, that ensure that 

funding allocations within the four required VOCA priority categories are accurately 

captured to ensure compliance with VOCA requirements. 

2 

42 
We recommend that OJP coordinate with the WA DOC on the appropriat.e :md 

reasonable submission of SARs for· its previously awarded VOCA subawards; and 

implement pmccdurcs to c1isu1·c that SARs arc submitted accumt.cly and in a timely 

manner to OVC. 

OJP agrees with this recommendation. We will coordinate with WA DOC to obtain 

evidence of submission ofSubgrant Award Reports (SARs) for its previously awarded 

VOC subawards, as appropriate. We will also coordinate with W ADOC to obtain a 

copy of written policies and procedures, developed and implemented, to ensure that 

f1.1ture S Rs are accurately and timely submitted to the Office for Victims of Crime 

(OVC). 

7. We recommend that OJP remedy 70,207 in inadequately supported expenditures. 

OJP agrees with this recommendation. We will review the $70,207 in questioned costs, 

related to inadequately supported expenditures, and will work with WA DOC to remedy, 

as appropriate. 

8. We recommend that OJP remedy $3,312 ofunsuppo11ed match contributions. 

OJP agrees with this recommendation. We will review the $3,312 in questioned costs, 

related to unsupported match contributions, and will work with WA DOC to remedy, as 

appropriate. 

9. We recommend that OJP ensure that the WA DOC and its pass-through agencies 

revise their financial monitoring policies and procedures to include the review of 

fiscal-related matters to mitigate the risk of commingling and unsupported 

subrecipient Requests for Reimbursement. 

OJP agrees with this recommendation. We will coordinate with WA DOC to obtain a 

copy of its revised and implemented fi nancial monitoring policies and procedure ·, lo 

ensure that WA DOC and its pass-through agencies include the review of fiscal-related 

matters to mitigate the risk of commingling and unsuppo1ted subrecipient Requests for 

Reimbur ·ement 

10. We recommend that OJP ensure the DSHS update its annual renewal application 

process of emergency domestic violence shelters to require a copy of the most recent 

annual safety inspedion repo1t from the local fire department. 

O.JP agrees with this recommendation. We will coordinate with WA DOC to obtain a 

copy of written policies and procedures, developed and implemented, to ensure that the 

State of Washington's Department of Social and Health Services (DSHS) update its 

aiurnal renewal application process of emergency domestic violence shelters, to require 

they obtain a copy of the most recent annual safety inspection report from the local fire 

department. 

3 

43 
We recommend that OJP ensure OCVA revise its CVSC service standards to 

include onsite monitoring plans. 

JP agrees with this recommendation. We will coordinate with WA DOC to obtain a 

copy of written policies and procedures, developed and implemented, to ensure that 

OCV A revises its Crime Victim Service Center (CVSC) setvice standards to include 

appropri ate onsite monitoring plans. 

We appreciate the opportunity to review and comment on the draft audit report. If you have any 

questions or require additional infonnation, please contact Jeffery A. Haley, Deputy Director, 

Audit and Review Division, on (202) 616-2936. 

cc: Katharine T. Sullivan 

Principal Deputy Assistant Attorney General 

Maureen A. Henneberg 

Deputy Assistant Attorney General 

for Operations and Management 

LeToya A. Johnson 

Senior dvisor 

Office of the Assistant Attorney General 

Jeffery . Haley 

Deputy Director, Audit and Review Division 

Office of Audit, Assessment, and Management 

Jessica E. Hart 

Director 

Office for Victims of Crime 

Bill Woolf 

Senior Advisor 

Office for Victims of Crime 

Katherine Darke-Schmitt 

Deputy Director 

Office for Victims of Crime 

Katlu·itia S. Peterson 

Acting Deputy Director 

Office for Victims ofCritne 

James Simonson 

Associate Director for Operation 

Office for Victitns of Crime 

4 

44 
Joel Hall 

s 'Ociale Director, Stale Victim Re ource Division 

Office for Victim. of Crime 

Shawn Cook 

Grants Management Specialist 

Office for Victims of Crime 

Charlotte Grzebien 

Deputy General Counsel 

Phillip K. Merkle 

cling Director 

Office of Communications 

Leigh A. Benda 

Chief Financial Officer 

Christal Mc eil-Wright 

Associate Chief Financial Officer 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Joanne M. Sutlington 

Associate Chief Financial Officer 

Finance, Accounting, and Analysis Division 

Office of the Chief Financial Officer 

Aida Brnmme 

Manager, Evaluation and Oversight Branch 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Louise Duhamel 

Acting Assistant Director, Audit Liaison Group 

Internal Review and Evaluation Office 

Justice Management Division 

O.JP Executive Secretariat 

Control umber 11'20200722111426 

5 

45 
 

 

 

 

 

 

 

 

 

 

APPENDIX 7 

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT 

The OIG provided a draft of this audit report to the State of Washington 

Department of Commerce (WA DOC) and the Office of Justice Programs (OJP). 

The WA DOC’s response is incorporated in Appendix 4; the Office of Civil Legal 

Aid’s (OCLA), one of the State of Washington’s pass-through agencies, response 

is incorporated in Appendix 5; and OJP’s response is incorporated in Appendix 6 

of this final report. In response to our draft audit report, OJP agreed with all 11 

recommendations. Thus, the status of the report is resolved. WA DOC concurred 

with all 11 recommendations. OCLA commented primarily on Recommendations 

7 and 8, and did not concur, in part, with the two recommendations, but 

proposed corrective actions to resolve them. The following provides the OIG 

analysis of the response and summary of actions necessary to close the report. 

Recommendations for OJP: 

1. Ensure that the WA DOC reevaluates its subaward funding practices 

and develops procedures to ensure that all grant recipients can 

accurately and separately account for awarded funds within their 

accounting systems and financial records. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of written policies 

and procedures, developed and implemented, to ensure that all 

subrecipients accurately and separately account for federal award funds 

within their accounting systems and financial records. As a result, this 

recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that it would work with OJP to evaluate its subaward funding 

practices and procedures to ensure that all grant recipients can accurately 

and separately account for awarded funds within their accounting systems 

and financial records. 

This recommendation can be closed when we receive documentation 

demonstrating that the WA DOC reevaluated its subaward funding practices 

and developed procedures to ensure that all grant recipients can accurately 

and separately account for awarded funds within their accounting systems 

and financial records. 

2. Ensure that the WA DOC develop a uniform policy for competitivelybid grant applications, outlining baseline bid review procedures. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of written policies 

and procedures, developed and implemented, to ensure that the WA DOC 

46 
 

 

 

 

 

includes baseline requirements for reviewing competitively-bid grant 

applications. As a result, this recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that it has begun working on a uniform procedure for all 

competitively-bid procurements from VOCA grant funds. 

This recommendation can be closed when we receive documentation 

demonstrating that the WA DOC developed a uniform policy for 

competitively-bid grant applications, outlining baseline bid review 

procedures. 

3. Ensure that the WA DOC establishes procedures in drafting victim 

assistance program subaward templates by coordinating with passthrough agencies to ensure consistency, accuracy, and compliance 

with federal regulations and VOCA guidelines. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it would coordinate with the WA DOC to obtain a copy of written 

policies and procedures, developed and implemented, for drafting victim 

assistance program award templates, by coordinating with pass-through 

agencies to ensure consistency, accuracy, and compliance with federal 

regulations and Victims of Crime Act (VOCA) guidelines. As a result, this 

recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that it has begun working on written procedures to ensure 

consistency, accuracy, and compliance with federal regulations and VOCA 

guidelines in its subaward contract template. 

This recommendation can be closed when we receive documentation 

demonstrating that WA DOC established procedures in drafting victim 

assistance program subaward templates by coordinating with pass-through 

agencies to ensure consistency, accuracy, and compliance with federal 

regulations and VOCA guidelines. 

4. Ensure that the WA DOC develop a comprehensive grants 

administration manual for OCVA to facilitate consistent 

administration of VOCA funds and compliance with the DOJ Grants 

Financial Guide. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of written policies 

and procedures, developed and implemented, for its Office of Crime Victims 

Advocacy (OCVA), to ensure consistent administration of VOCA funds and 

compliance with the Department of Justice (DOJ) Grants Financial Guide. 

As a result, this recommendation is resolved. 

47 
 

 

 

 

 

 

The WA DOC concurred with our recommendation and stated in its 

response that staff has begun working on a comprehensive grants 

administration manual. 

This recommendation can be closed when we receive evidence that the 

WA DOC has developed a comprehensive grants administration manual for 

OCVA to facilitate consistent administration of VOCA funds and compliance 

with the DOJ Grants Financial Guide. This comprehensive grants 

administration manual should integrate policies and procedures resulting 

from other recommendations of this report: separate accounting for 

awarded funds by all grant recipients; uniform policy for competitively-bid 

grant applications; consistent and accurate subaward templates; accurate 

capture of funding allocation for the priority categories; submission of 

accurate Subgrant Award Reports (SAR) in a timely manner; financial 

monitoring policies; and the CVSC onsite monitoring procedures. 

5. Ensure that the WA DOC develop procedures to accurately capture 

its funding allocation to the four required VOCA priority categories 

to ensure compliance with VOCA requirements. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of written policies 

and procedures, developed and implemented, to ensure that funding 

allocations within the four required VOCA priority categories are accurately 

captured in compliance with VOCA requirements. As a result, this 

recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that its staff has begun working on a written procedure outlining 

how the VOCA priority categories would be tracked to ensure compliance. 

This recommendation can be closed when we receive documentation that 

the WA DOC developed procedures to accurately capture its funding 

allocation to the four required VOCA priority categories to ensure 

compliance with VOCA requirements. 

6. Coordinate with the WA DOC on the appropriate and reasonable 

submission of SARs for its previously awarded VOCA subawards; 

and implement procedures to ensure that SARs are submitted 

accurately and in a timely manner to OVC. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain evidence of submission of 

SARs for its previously awarded VOCA subawards, as appropriate. In 

addition, OJP will coordinate with the WA DOC to ensure that it has 

developed and implemented policies and procedures for filing future SARs 

that are accurate and submitted in a timely manner to Office for Victims of 

Crime (OVC). As a result, this recommendation is resolved. 

48 
 

 

 

 

 

 

 

 

 

The WA DOC concurred with our recommendation and stated in its 

response that it has been assessing staff resources to allocate additional 

staff to SARs. 

This recommendation can be closed when we receive evidence that the 

WA DOC: (1) has submitted SARs for previously awarded VOCA subawards 

that were deemed appropriate and reasonable by OJP, and 

(2) implemented policies and procedures to ensure that SARs are submitted 

accurately and in a timely manner to OVC. 

7. Remedy $70,207 in inadequately supported expenditures. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will review the $70,207 in questioned costs, related to inadequately 

supported expenditures, and will work with the WA DOC to remedy, as 

appropriate. As a result, this recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that it will work with OJP to resolve this issue. 

OCLA did not concur with a portion of the questioned costs in this 

recommendation associated with Subrecipient 1. OCLA stated that 

Subrecipient 1’s employees were 100 percent dedicated to VOCA work. 

However, we were not provided documentation during our audit testing 

that demonstrated the employees were 100 percent dedicated to VOCA 

work, such as timesheets, personnel activity reports, or time certifications. 

In addition, OCLA stated that the issue appeared to be an internal control 

issue of documentation rather than an unallowable questioned cost. We 

agree; our report classified these questioned the costs as unsupported, not 

unallowable. 

As a corrective action, OCLA stated that its subrecipient will improve its 

internal controls by instituting a semi-annual certification protocol pursuant 

to which staff dedicated exclusively to VOCA-funded work will document the 

same. Allocation of personnel expenses for staff (if any) engaged in a mix 

of VOCA and non-VOCA funded work will be documented by timesheets 

backed up by contemporaneous timekeeping records. 

This recommendation can be closed when we receive evidence that OJP 

remedied the $70,207 in inadequately supported expenditures. 

8. Remedy $3,312 of unsupported match contributions. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will review the $3,312 in questioned costs, related to unsupported 

match contributions, and will work with WA DOC to remedy, as appropriate. 

As a result, this recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that it will work with OJP to resolve this issue. 

49 
 

 

 

 

 

 

 

 

OCLA did not concur with a portion of the questioned costs in this 

recommendation associated with one of its subrecipients. While OCLA’s 

subrecipient recognized that the survey used to support its match 

contribution rate was no longer available, OCLA disagreed with the hourly 

rate used by the OIG. In addition, OCLA stated that its subrecipient 

exceeded the match hours for FY 2019, which the OIG did not take into 

consideration. During our audit, we selected a limited sample of OCLA’s 

subrecipient match contributions for testing. Out of our sample of 10.30 

hours, we found 5.9 hours, or 57 percent, to be unsupported. OCLA’s 

subrecipient agreed that the 5.9 hours were erroneously recorded and did 

not provide other costs in lieu of the erroneous 5.9 hours. 

As a corrective action, OCLA stated that it will require its subrecipient to 

conduct biennial market surveys of its volunteer attorneys to establish 

meaningful and objectively supportable match values. If needed, the 

subrecipient will also submit cash from other sources as part of the 

allowable match for the audited period in question. 

This recommendation can be closed when we receive evidence that OJP 

remedied the $3,312 of unsupported match contributions. 

9. Ensure that the WA DOC and its pass-through agencies revise their 

financial monitoring policies and procedures to include the review 

of fiscal related matters to mitigate the risk of commingling and 

unsupported subrecipient Requests for Reimbursement. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of its revised and 

implemented financial monitoring policies and procedures, to ensure that 

the WA DOC and its pass-through agencies include the review of fiscalrelated matters to mitigate the risk of commingling and unsupported 

subrecipient Requests for Reimbursement. As a result, this 

recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that, as of July 1, 2020, the VOCA Victim Assistance program 

implemented revised fiscal monitoring procedures to include review of 

fiscal-related matters. The WA DOC stated it will review these procedures 

with OJP. 

This recommendation can be closed when we receive documentation 

demonstrating that the WA DOC and its pass-through agencies revised their 

financial monitoring policies and procedures to include the review of fiscal 

related matters to mitigate the risk of commingling and unsupported 

subrecipient Requests for Reimbursement. 

50 
 

 

 

 

 

 

 

10. Ensure the DSHS update its annual renewal application process of 

emergency domestic violence shelters to require a copy of the most 

recent annual safety inspection report from the local fire 

department. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of written policies 

and procedures, developed and implemented, to ensure that the state of 

Washington’s Department of Social and Health Services (DSHS) update its 

annual renewal application process of emergency domestic violence 

shelters, to require that they obtain a copy of the most recent annual safety 

inspection report from the local fire department. As a result, this 

recommendation is resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that the DSHS has added a requirement to include a copy of the 

annual safety inspection report to its application process. 

This recommendation can be closed when we receive evidence that the 

DSHS has updated its annual renewal application process of emergency 

domestic violence shelters to require a copy of the most recent annual 

safety inspection report from the local fire department, which would 

demonstrate that the applicants have received the required annual safety 

inspection from the local fire department, and that they have resolved all 

safety issues identified. 

11. Ensure OCVA revise its CVSC service standards to include onsite 

monitoring plans. 

Resolved. OJP agreed with our recommendation and stated in its response 

that it will coordinate with the WA DOC to obtain a copy of written policies 

and procedures, developed and implemented, to ensure that OCVA revises 

its Crime Victim Service Center (CVSC) service standards to include 

appropriate onsite monitoring plans. As a result, this recommendation is 

resolved. 

The WA DOC concurred with our recommendation and stated in its 

response that it will add onsite monitoring procedures to the CVSC service 

standards document. 

This recommendation can be closed when we receive policies and 

procedures demonstrating that OCVA revised its CVSC service standards to 

include onsite monitoring plans. 

51