Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Office of Justice Programs 

Victim Compensation Grants Awarded 

to the Wyoming Office of the Attorney 

General, Cheyenne, Wyoming

REDACTED FOR PUBLIC RELEASE

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

Appendix 4, the grantee’s response, and are the names of an individual and a third-party company. 

Audit Division 20-039 March 2020
i

Executive Summary

Audit of the Office of Justice Programs Victim Compensation Grants 

Awarded to the Wyoming Office of the Attorney General, 

Cheyenne, Wyoming

Objective

The objective of the audit was to evaluate how the 

Wyoming Crime Victim Compensation Program (WCVCP)

designed and implemented its crime victim 

compensation program, which receives Victims of Crime 

Act (VOCA) funding. 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, and (3) grant financial management.

Results in Brief

As a result of our audit, we concluded that the WCVCP 

established an adequate program to compensate victims 

and survivors of criminal violence. We did not identify 

concerns with administrative costs, drawdown 

procedures, financial reports, and the three special 

conditions we selected for testing. However, we 

identified issues with the lack of policies and procedures 

related to program performance reports. We also 

identified errors in the state certification form for fiscal 

years (FY) 2013 through 2017, resulting in the WCVCP 

receiving $822,000 in excess grant funds. Our audit 

additionally identified $16,345 in unsupported 

expenditures and $1,791 in unallowable expenditures 

charged to the grant. However, after issuing the draft 

report, OJP deobligated $360,986 to address these 

deficiencies. Therefore, our final report identifies

$479,150 in questioned costs and funds to be put to 

better use. 

Recommendations

Our report contains eight recommendations to the Office 

of Justice Programs (OJP) to assist the WCVCP in 

improving its grant management and administration. 

We discussed the results of our audit with OJP and 

WCVCP officials and have included their comments in the 

report. Their responses can be found in Appendices 3 

and 4, respectively. Our analysis of those responses is 

included in Appendix 5.

Audit Results

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

General completed an audit of four VOCA victim 

compensation formula grants awarded by the OJP, Office 

for Victims of Crime (OVC) to the Wyoming Office of the 

Attorney General. The OVC awarded these formula 

grants, totaling $2,418,000 from FY 2015 through 2018,

from the Crime Victims Fund to provide financial support 

through the payment of compensation benefits to crime 

victims throughout Wyoming. As of November 2019,

the WCVCP drew down a cumulative amount of

$1,889,190 for all of the grants we reviewed.

Planning and Execution – The WCVCP enhanced

public awareness of victim compensation benefits for 

crime victims. However, we found that the WCVCP’s 

policies and procedures were not updated to include 

specific details on processing payments for the victim 

compensation program and did not have written 

procedures for addressing potential refunds, as 

recommended by OJP’s Office of the Chief Financial 

Officer. Furthermore, WCVCP did not correctly calculate 

the amounts reported on the annual state certification 

forms. As a result, the WCVCP overstated the amount 

submitted on the line item, “Total State Payments 

Eligible for Matching VOCA Grant Award,” and was 

awarded a cumulative excess amount of $822,000 for 

FYs 2015 through 2019 grants. However, after issuing 

the draft report, OJP deobligated $26,000 in unallowable 

costs and $316,850 in funds to be put to better use. 

Therefore, we question the remaining $469,799 as 

unallowable and identify $9,351 as funds that should be 

put to better use.

Program Requirements and Performance 

Reporting – We found that the WCVCP complied with 

the three special conditions tested. However, we found 

that the WCVCP was unable to support some of its 

performance data and did not retain the original queries 

of performance metrics used to support the performance 

measures it reported to the OVC.

Grant Financial Management – The WCVCP generally 

implemented adequate controls over claim payments 

and administrative expenditures. However, we found 

that WCVCP did not always obtain adequate 

documentation for claim payments.
AUDIT OF THE OFFICE OF JUSTICE PROGRAMS

VICTIM COMPENSATION GRANTS AWARDED TO

THE WYOMING OFFICE OF THE ATTORNEY GENERAL,

CHEYENNE, WYOMING

TABLE OF CONTENTS

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

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

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

AUDIT RESULTS.............................................................................................3

Grant Program Planning and Execution ....................................................3

Program Implementation ..............................................................3

Annual State Certification .............................................................4

Program Requirements and Performance Reporting...................................7

Annual Performance Reports .........................................................7

Compliance with Special Conditions................................................9

Grant Financial Management ..................................................................9

Grant Expenditures .................................................................... 10

Drawdowns ............................................................................... 13

Financial Reporting .................................................................... 14

CONCLUSION AND RECOMMENDATIONS......................................................... 15

APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY ................................... 17

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS................................ 19

APPENDIX 3: U.S. DEPARTMENT OF JUSTICE OFFICE OF JUSTICE PROGRAMS 

RESPONSE TO THE DRAFT AUDIT REPORT ............................................. 20

APPENDIX 4: WYOMING OFFICE OF THE ATTORNEY GENERAL DIVISION OF VICTIM 

SERVICES RESPONSE TO THE DRAFT AUDIT REPORT .............................. 25

APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY OF 

ACTIONS NECESSARY TO CLOSE THE REPORT........................................ 32
1

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS

VICTIM COMPENSATION GRANTS AWARDED TO

THE WYOMING OFFICE OF THE ATTORNEY GENERAL, 

CHEYENNE, WYOMING

INTRODUCTION

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

completed an audit of four victim compensation formula grants awarded by the 

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

Office of the Attorney General, Division of Victim Services (DVS) in Cheyenne, 

Wyoming. The OVC awards victim compensation 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 $2,418,000.

Table 1

Audited Grants

Fiscal Years 2015 – 2018

Award Number Award Date Award Period 

Start Date

Award Period 

End Date Award Amount

2015-VC-GX-0051 08/25/2015 10/01/2014 09/30/2018 $683,000

2016-VC-GX-0044 09/19/2016 10/01/2015 09/30/2019 714,000

2017-VC-GX-0072 09/28/2017 10/01/2016 09/30/2020 473,000

2018-V1-GX-0019 08/09/2018 10/01/2017 09/30/2021 548,000

Total: $2,418,000

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. VOCA victim compensation 

formula grant funds are available each year to states and territories for distribution

to eligible recipients.

The primary purpose of the victim compensation grant program is to 

compensate victims and survivors of criminal violence for: (1) medical expenses 

attributable to a physical injury resulting from a compensable crime, including 

expenses for mental health counseling and care; (2) loss of wages attributable to a 

 1 The VOCA victim compensation formula program is funded under 34 U.S.C. § 20102.
2

physical injury resulting from a compensable crime; and (3) funeral expenses 

attributable to a death resulting from a compensable crime.2

The Grantee

As the Wyoming state administering agency, the Wyoming Office of Attorney 

General received the VOCA funding. Within the Wyoming Office of Attorney General 

is the Wyoming Crime Victim Compensation Program (WCVCP). The WCVCP 

consists of personnel from DVS and the Fiscal Section. The DVS is responsible for 

administering the WCVCP. DVS is solely responsible for processing applications and 

claims, and the actual claim payments are processed separately by the Fiscal 

Section. The WCVCP provides financial assistance to hundreds of victims each year.

Victim compensation payments are awarded for out-of-pocket expenses, medical 

expenses, lost wages, and counseling costs related to emotional and physical injury 

suffered by the victim and the victim’s family as a direct result of a crime. The 

compensation program helps innocent victims and their families pay for the 

financial cost of crime.

OIG Audit Approach

The objective of the audit was to evaluate how WCVCP designed and 

implemented the crime victim compensation 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, and (3) grant financial management.

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 compensation program guidelines (VOCA 

Guidelines), and the DOJ Grants Financial Guide as our primary criteria. We also 

reviewed relevant Wyoming policies and procedures, such as the Wyoming Crime 

Victim Compensation Act, and interviewed Wyoming personnel to determine how 

they administered the VOCA funds. We obtained and reviewed Wyoming records 

reflecting grant activity.3

 2 This program defines criminal violence to include drunk driving and domestic violence.

3 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.
3

AUDIT RESULTS

Grant Program Planning and Execution

The main purpose of the VOCA victim compensation grants is to enhance 

state victim compensation payments to eligible crime victims. As part of our audit, 

we assessed the WCVCP’s overall process for making victim compensation 

payments. We assessed WCVCP’s policies and procedures for providing 

compensation payments to victims, as well as the accuracy of the state certification 

form.

Overall, we determined that the WCVCP’s implementation of its victim 

compensation program was appropriate and generally in compliance with the VOCA

Guidelines. We found that the WCVCP complied with federal grant requirements 

and established an adequate program to compensate victims and survivors of 

criminal violence. However, we identified issues with the WCVCP’s written policies 

and procedures and the accuracy of its annual state certification forms.

Program Implementation

State administering agencies receive VOCA victim compensation grants to 

compensate victims for expenses incurred from criminal victimization. For

Wyoming, the WCVCP within the Wyoming Office of Attorney General, is responsible 

for the victim compensation program, including meeting all financial and 

programmatic requirements. When paying claims for victims, the WCVCP operated 

under the Wyoming Crime Victim Compensation Act, the Wyoming Compensation 

Guidelines Policy, and the Wyoming Financial Administrative Guide, which conveyed 

the state-specific policies for its victim compensation program. In assessing the

WCVCP’s implementation of its victim compensation program, we analyzed policies 

and procedures governing the decision-making process for individual compensation 

claims, as well as what efforts the WCVCP had made to bring awareness to victims 

eligible for compensation program benefits.

Policies and Procedures

In May 2018, OJP’s Office of the Chief Financial Officer (OCFO) conducted a 

financial monitoring and technical assistance site visit, in part to determine if 

adequate policies and procedures were in place to ensure federal funds were used 

for authorized purposes.4 In its report, the OCFO provided findings and 

recommendations, which were intended to improve accounting practices and 

strengthen internal controls. Specifically, the OCFO found that the Wyoming Office 

of the Attorney General maintained general written accounting policies; however, it 

also noted that these policies lacked specific provisions for managing Federal funds, 

including procedures for completing the annual state certification form, processing

victim payments, and any other pertinent grant-related financial activities.

 4 The OCFO site visit reviewed the financial aspects for 15 grants awarded by the DOJ to the 

Wyoming Office of the Attorney General, which included 2 awards in the scope of our audit, Award 

Numbers 2015-VC-GX-0051 and 2016-VC-GX-0044.
4

In an effort to address the OCFO recommendations, in October 2018, the

WCVCP implemented the Wyoming Victim Compensation Certification Form Policy, 

which included specific detailed procedures for completing the annual state 

certification form. Additionally, we reviewed the WCVCP’s established policies and 

procedures for accepting, recording, and reviewing applications for victim 

compensation and found that the WCVCP relied upon the Wyoming Crime Victim 

Compensation Act, the Wyoming Compensation Guidelines Policy, and the Wyoming 

Financial Administrative Guide for determining the eligibility of claims and limits on 

allowable payments. These policies and procedures appear to be consistent with 

VOCA Guidelines and contained guidance on many of the common types of claims 

the WCVCP receives. However, we also found that although the OCFO closed its 

report in January 2019, the WCVCP’s policies and procedures were not updated to 

include specific detail on processing payments for the victim compensation 

program, as the OCFO had recommended. As a result, we recommend OJP work 

with the WCVCP to include detailed policies and procedures related to victim 

payments to ensure that when applicable personnel are unavailable, or other 

changes resulting in the loss of institutional knowledge occur, the WCVCP remains 

compliant with its VOCA victim compensation requirements.

Furthermore, the WCVCP’s policies and procedures were not updated to 

include other pertinent grant-related financial activities. Specifically, we found that 

the WCVCP did not have written procedures for addressing potential refunds. 

Therefore, to better administer the victim compensation program, we recommend 

OJP ensure the WCVCP develop a written procedure for refunds.

Program Outreach

According to WCVCP, efforts have been made to enhance public awareness of 

available victim compensation benefits. Based on our review, we found that the 

WCVCP provides training about the victim compensation program to all victim 

advocates funded through its victim assistance program. This training, provided 

every 2 years, informs the advocates about the victim compensation program’s 

mission, policies and procedures, reporting requirements, and the decision-making 

process for victim compensation claims. We also found that the WCVCP website 

describes the benefits available to victims or claimants, details the compensation 

program and process, and provides access to several different forms, including the 

crime victim compensation application form. Further, DVS officials stated they

work with the local news media to highlight the program. The WCVCP enhanced 

public awareness of victim compensation benefits for crime victims in a variety of 

ways, and we encourage the WCVCP to continue exploring initiatives to increase 

public awareness of its WCVCP.

Annual State Certification

State administering agencies must submit an annual Crime Victim 

Compensation State Certification Form, which provides the OVC with the necessary 

information to determine the next grant award amount. The certification form must 

include all sources of revenue to the crime victim compensation program during the 

federal fiscal year, as well as the total of all compensation claims paid out to, or on
5

behalf of, victims from all funding sources. The OVC allocates VOCA victim 

compensation formula grant funds to each state by calculating 60 percent of the 

eligible compensation claims paid out to victims during the fiscal year 2 years 

prior.5 The accuracy of the information provided in the certification form is critical 

to OJP’s correct calculation of the victim compensation award amounts granted to

each state.

We assessed the annual state certification forms submitted by the WCVCP to 

the OVC for FYs 2013 through 2018, which determine the amount of funds awarded

in FYs 2015 through 2020.6 Our review focused on the accuracy of the annual state 

certification forms, including total funds paid, payouts made with VOCA funds, 

subrogation recoveries, restitution recoveries, refunds, and other reimbursements. 

Using official accounting records provided by the Fiscal Section, we attempted to 

reconcile the figures reported. We determined that the WCVCP did not correctly 

calculate the amounts it reported on its annual state certification forms.

According to the certification form instructions, States are prohibited from 

including administrative costs in the line item “Total amount paid to or on behalf of 

crime victim from all funding sources.” Furthermore, this line item should only 

include payments made by the compensation program to, or on behalf of, victims of 

crime. However, we found that the WCVCP included in its FY 2013 through 2017 

certification forms a State funding source which included administrative costs and 

funds other than those paid to or on behalf of crime victims.

Furthermore, for the certification forms capturing activity in FYs 2013 and 

2014, there were additional transactions excluded and transposed when calculating 

the line item for total amount of payments made, accordingly. The amount recorded 

for FY 2013 total payments made did not include refund transactions. This resulted 

in an inaccurately high total of reported payments. The amount recorded for FY 2014,

total payments made included an amount that was recorded incorrectly. The 

amount should have been recorded as a negative amount; however, the Fiscal 

Section recorded it as a positive amount. Accordingly, the FY 2014 amount for this 

field was also inaccurately high.

In addition, we found the WCVCP also made errors in recording totals that 

need to be deducted for its award certification. For FYs 2013 and 2014, we found 

the WCVCP underreported its deduction amount because the Fiscal Section 

incorrectly excluded the revenue funding source “unclaimed property” from this 

amount.7

 5 The eligible payout amount for award consideration is determined after deducting payments 

made with VOCA funds, subrogation and restitution recoveries, refunds, amounts awarded for 

property loss, and other reimbursements.

6 The OJP’s Office of the Chief Financial Officer, Budget Execution Division calculates the 

allocations for VOCA eligible crime victim compensation programs and OVC makes the grant awards. 

In addition, the FY 2020 grant has yet to be awarded.

7 The revenue funding source is restitution that was returned to the State but for some 

reason it could not be traced back to a specific claim.
6

For these reasons, we found that the WCVCP overstated the line item “Total 

State Payments Eligible for Matching VOCA Grant Award” for FYs 2013 through 

2017 annual state certification forms. Given that the award cycle relies upon the 

recorded fiscal activity from 2 years prior, this resulted in excess award amounts of

$822,000 for FYs 2015 through 2019 grants, as shown in Table 2.

Table 2

Comparison of Wyoming Annual State Certification

Forms and the OIGs Recalculation of Formula Awards

State-Certified Eligible Amounts

FY 2013 

Form

FY 2014 

Form

FY 2015 

Form

FY 2016 

Form

FY 2017 

Form

FY 2018 

Form

WY Certification 

Form $1,138,946 $1,190,509 $788,686 $913,797 $1,105,771 $773,829

OIG Calculation 764,282 893,890 588,866 641,546 876,348 773,829

Difference $374,664 $296,619 $199,820 $272,251 $229,423 $0

VOCA Victim Compensation Formula Grant Award Amounts

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 Total

Award Amount $683,000 $714,000 $473,000 $548,000 $663,000

OIG Calculation of 

Award Amount 459,000 536,000 353,000 385,000 526,000

Award Amount 

Difference $224,000 $178,000 $120,000 $163,000 $137,000 $822,000

Note: The grant award amounts and the OIG Calculation of Awarded Amount are round to the 

nearest thousandth. Also, the grant award amounts are based on the annual state certification 

and accounting record figures from the fiscal year 2 years prior.

Source: OIG analysis of the WCVCP Section financial records and OVC documents.

In the event of an over certification, the Victim Compensation Grant Program 

Guidelines state that necessary steps will be taken to recover funds that were 

awarded in error, and that it is the policy of OVC to generally reduce the amount of 

the subsequent year VOCA victim compensation award by the amount of the 

overpayment. The WCVCP expended $495,799 of the excess award amount, which 

we identified in a draft of this report as unallowable. Subsequent to the issuance of

the draft report, OJP deobligated $26,000 of the initially questioned costs. As a 

result, we consider the $26,000 to be adequately addressed. Therefore, we 

recommend that OJP work with the WCVCP to remedy the remaining $469,799 in 

excess grant funds awarded for the FYs 2015 through 2017 grants. As of

November 2019, the WCVCP had not drawn down the $326,201 in excess funds for 

the FYs 2016 through 2019 grants. However, subsequent to the issuance of the 

draft report OJP deobligated $316,850 of the initially excess funds. As a result, we 

consider the $316,850 to be adequately addressed. Therefore, we also recommend 

that OJP work with the WCVCP to remedy the remaining $9,351 as funds to be put 

to better use.
7

Program Requirements and Performance Reporting

To determine whether the WCVCP distributed VOCA victim compensation

program funds to compensate victims of crime, we reviewed the WCVCP

performance measures and performance documents used to track goals and 

objectives. We further examined OVC solicitations and award documents and 

verified WCVCP’s compliance with special conditions governing recipient award 

activity.

Based on our overall assessment in the areas of program requirements and 

performance reporting, we found that the WCVCP complied with the special 

conditions tested. However, as detailed in the following section, we also found that

WCVCP could improve the policies and procedures used to compile its annual 

performance reports.

Annual Performance Reports

Each state administering agency must annually report to the OVC on activity 

funded by any VOCA awards active during the federal fiscal year. The reports are 

submitted through OJP’s Grants Management System (GMS). The OVC also began 

requiring states to submit quarterly performance data through the web-based 

Performance Measurement Tool (PMT). After the end of the fiscal year, the WCVCP

is required to produce the Annual State Performance Report and load it to GMS.

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

victims for whom an application was made; the number of victims whose 

victimization is the basis for the application; victim demographics; the number of 

applications that were received, approved, denied, and closed; and total 

compensation paid by service type. Table 3 shows a summary of the WCVCP’s 

annual reports.

Table 3

Summary from WCVCP Annual State Performance Report

Performance Categories FY 2015 FY 2016 FY 2017 FY 2018

Number of Claims Paida 455 774 945 1,001

Number of Applications Received 609 638 780 860

Number of Applications Approved 516 573 735 739

Number of Applications 

Denied/Closed 93 46 48 66

Total Amount of Claims Paid $915,702 $1,399,429 $1,417,888 $1,510,054

a Multiple claims can be paid to or on behalf for a single victim. These totals count each payment as a 

different claim.

Source: The WCVCP Annual State Performance Reports for FY 2015 through 2018.

We assessed whether the WCVCP’s annual performance data reported to the 

OVC fairly reflected the performance figures of the victim compensation program
8

activities by comparing the data the WCVCP reported to the data it had recorded in 

its internal tracking system.8 To this end, we selected one quarter from the 

FYs 2017 and 2018 yearly performance reports and tested metrics from every 

applicable category. Based on our review, we determined that the performance 

data did not match precisely, with some metrics being under reported and others 

over reported. We tested 70 performance metrics and found discrepancies in 21 of 

those metrics, or 30 percent. In Table 4, below, we included the three performance 

metrics from each performance report with the largest discrepancies.

Table 4

Differences of the Performance Report Metrics

FY 

Quarter Performance Metric Sub Metric

Progress 

Report

Supporting 

Documents Difference

2017 Q4 Population 

Demographics

Applications for 

Victim Comp 197 214 17

2017 Q4 Performance Measures New Application 

Received 194 213 19

2017 Q4 Performance Measures Application 

Approved 183 197 14

2018 Q2 Victim Demographics Age: Not Reported 4 1 (3)

2018 Q2 Performance Measures Applications 

Approved 199 204 5

2018 Q2 Performance Measures

Application received 

for Sexual Assault 

Forensic Exam

21 0 (21)

Source: The WCVCP Annual Performance Reports for FYs 2017 and 2018.

The DVS officials did not retain the original queries used to generate the 

supporting information from its internal tracking system, therefore, they could not 

explain why there were differences identified in the metrics reviewed.

A DVS official reproduced the supporting information from their internal 

tracking system at the time of our fieldwork. In order to verify this data, we then 

traced a sample of 40 victims to their victim files. Based on our analysis we 

identified three instances where the victim’s age was incorrect. DVS has since 

corrected the errors. Based on our analysis, except for the discrepancies noted 

above, we found the supporting information from WCVCP’s internal tracking system 

to be generally reliable.

Overall, we found the WCVCP lacked policies and procedures related to 

maintenance of valid and auditable source documentation. In our judgement, 

accurate statistics are a vital tool for OVC to use to better manage the victim 

compensation program. Retaining contemporaneous records when submitting PMT 

 8 The DVS uses an electronic case management system (CCVC) to prepare its quarterly and 

annual performance reports.
9

reports to OVC would enable WCVCP to more readily demonstrate that reported 

data accurately reflected its performance at the time of reporting. Therefore, we 

recommend OJP work with WCVCP to create policy or procedures to ensure that it 

maintains support for the performance data used at the time of reporting to OVC 

and thereby enable reconciliation of reported data with its internal records.

Compliance with Special Conditions

The special conditions of a federal grant award establish specific 

requirements for grant recipients. In its grant application documents, the WCVCP

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

conditions for each VOCA victim compensation program grant and identified three 

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

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

tested required that:

• The recipient agrees to submit quarterly performance reports on the 

performance metrics identified by OVC, and in the manner required by OVC.

• The recipient agrees to ensure that at least one key grantee official attends 

the annual VOCA National Training Conference. Any recipient unable to 

attend must get prior approval by OVC in writing.

• Both the Point of Contact and all Financial Points of Contact for this award 

must have successfully completed an “OJP financial management and grant 

administration training,” by 120 days after the date of the recipient’s 

acceptance of the award.

Based on our analysis, the WCVCP was in compliance with the grant special 

conditions we analyzed.

Grant Financial Management

Award recipients must establish an adequate accounting system and 

maintain financial records that accurately account for awarded funds. To assess the 

adequacy of the WCVCP’s financial management of the VOCA victim compensation 

grants, we reviewed the process used to administer these funds by examining 

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

financial reports. We also reviewed the Single Audit Reports for FYs 2015 to 2018. 

These Single Audits did not identify significant deficiencies or material weaknesses 

specific to the victim compensation program.

Finally, we interviewed WCVCP personnel who were responsible for financial 

aspects of the grants; reviewed WCVCP written policies and procedures; and 

inspected award documents, drawdown procedures, and the preparation and 

submission of financial records.

As discussed below, in our overall assessment of grant financial 

management, we determined that the WCVCP generally implemented adequate 

controls over claim payments and administrative expenditures associated with 
10

managing the victim compensation program. However, we also identified

unsupported and unallowable expenditures charged to the grants. 

Grant Expenditures

State administering agency VOCA compensation expenses fall into two 

overarching categories: (1) compensation claim payments – 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.

Victim Compensation Claim Expenditures

Victims of crime in the state of Wyoming submit claims for reimbursement of 

expenses incurred as a result of victimization, such as medical and funeral costs or 

loss of wages. WCVCP staff adjudicate these claims for eligibility and make 

payments from the VOCA victim compensation grants and state funding.

To evaluate the WCVCP’s financial controls over VOCA victim compensation 

grant expenditures, we judgmentally selected 150 claims that totaled $175,342 

from the audited awards. These claims included costs for funeral services, lost 

wages, prescription medication, ambulance services, dental and hospital visits,

chiropractor services, and mental health counseling.

We found that WCVCP did not always obtain adequate documentation for 

claim payments, or perform secondary review of claims, resulting in errors 

calculating claim reimbursement amounts. Of the 150 claims reviewed, we 

identified 15 claims that included unsupported and/or unallowable costs. Our 

findings are discussed in greater detail in the following sections of the report.

• Lost Wage Verification

The Wyoming Compensation Guidelines Policy allows victims to be 

reimbursed for up to 3 months of wages, not exceeding the federal minimum hourly 

wage rate. According to the Wyoming Compensation Guidelines Policy, the WCVCP 

may pay a victim for:

• Wages lost due to serious injury as a result of a crime.

• Wages lost while receiving medical treatment or counseling.

• Wages lost because of permanent disability.

• Wages lost because the victim is attending the sentencing of the offender 

and providing a victim impact statement.

In order to be eligible for lost wage payment due to an injury, the Wyoming 

Victim Compensation Guidelines Policy required WCVCP to obtain (1) verification 
11

from a physician or mental health service provider and (2) an employer certification 

form or federal tax statement if self-employed.9

Of the 150 claims we reviewed, there were a total of 10 claims that were for 

lost wages. We found that WCVCP officials did not obtain the required physician or 

mental health service provider verification for 9 of the claims reviewed.10 In 

response to our concerns about the missing verifications, WCVCP officials informed 

us that they were removing the requirement for a physician or mental health 

service provider verification from the Wyoming Victim Compensation Guidelines 

Policy.

Although we found that the WCVCP relied on police reports to support that a 

crime was committed, the employer or self-employed certification form for the

hours/days of work missed for the lost wage claim payment, and medical invoices 

to support that the crime resulted in medical treatment; we fundamentally disagree 

with WCVCP’s decision to remove the physician or mental health service provider 

verification requirement and believe that relying on medical invoices to support that 

the crime resulted in medical treatment may not provide all the necessary and 

verifiable support for the time needed to recover from a crime related 

injury. Specifically, by removing the verification requirement, WCVCP officials 

become the de facto physician or mental health provider required to make 

judgments on the severity of a victim’s injuries, the time needed to recover from 

those injuries, and ultimately on the legitimacy of a victim’s lost wage claim. In our 

judgement, federal funds used for lost wages that are not supported by

documentation from a physician or mental health provider, or similar 

documentation, may be at a greater risk for waste, fraud, and abuse. As a result, 

we recommend that OJP work with WCVCP to strengthen its current policies and 

procedures to ensure it obtains all necessary documentation to support any lost 

wage amount paid.

• Other Lost Wage Claims

In addition to the lost wage verification discussed above, we identified four

lost wage claims with questioned costs. For one claim, WCVCP paid a family 

member $341, for 47 hours of lost wages to bereave the death of a sibling.11

However, the Wyoming Victim Compensation Guidelines Policy only allows for wage 

loss to be reimbursed to an associated victim for:

• Wages lost during travel time to be with a critically injured victim.

 9 The Employment Verification Form is used to determine whether the victim was employed at 

the time of the crime and to collect the necessary information related to number of hours worked and 

dates of missed work.

10 Of the 10 lost wage claims there was 1 claim for bereavement, which a physician or mental 

health service provider verification would not be applicable. However, this claim is discussed 

subsequently in this report in the Other Lost Wage Claims section.

11 The family member worked 20-25 hours a week, which the WCVCP payed a two week lost 

wage claim.
12

• Wages lost while attending to a critically injured victim.

• Wages lost while transporting victim to medical treatment, counseling, or 

sentencing when the victim is providing a victim impact statement.

Since the Wyoming Victim Compensation Guidelines Policy does not include 

bereavement for the loss of a loved one as an allowable expense, we are 

questioning the claim as unallowable. 

For another claim, WCVCP paid a victim for 45 days of missed work, although 

the employer verification form provided indicated that the victim had not worked 

there for more than 5 weeks. The Wyoming Victim Compensation Guidelines Policy 

states that if the victim was employed for less than the 6 months preceding their

victimization, payment for lost wages shall not exceed the amount of time the

victim had worked prior to their victimization. When we asked for support for the 

45 days, DVS officials indicated they should have only approved payment for 25 days

based on the number of days the victim had been employed prior to the crime. 

Therefore, we are questioning the additional 20 days paid, totaling $986 in 

unsupported costs. 

Finally, for two lost wage claims, the WCVCP did not receive a federal tax 

return for the self-employed victim, as required by the Wyoming Victim 

Compensation Guidelines. Instead, WCVCP obtained a notarized self-employed 

verification of lost wages form. Therefore, we are questioning these two claims, 

totaling $4,179, as unsupported costs. 

• Other Claims

We identified 11 other claims with unsupported and unallowable costs. The 

unsupported costs included expenses for prescription medication, travel/mileage, 

medical treatment, and mental health counseling. The unallowable costs included 

expenses for travel/mileage, and per diem. The issues identified were for 

miscalculations, inadequate support, or did not follow the Wyoming Victim 

Compensation Guidelines Policy for max allowance. Therefore, we are questioning 

the 11 claims, totaling $11,180 in unsupported and $1,450 in unallowable 

expenditures charged to the VOCA victim compensation program grants. 

In total, we identified $16,345 in unsupported and $1,791 in unallowable 

expenditures charged to the grants, which OJP deobligated and adequately 

remedied subsequent to the issuance of our draft report.12 As a result, we consider 

these costs to be adequately addressed. 

Furthermore, in our judgment, the WCVCP should enhance its claims 

reviewing process by implementing a secondary review in order to mitigate the risk 

of misapplication of the crime victim compensation funds in the future. We 

discussed this issue with DVS officials during the course of our audit, and DVS 

 12 In response to the draft report, the WCVCP provided additional documentation that would 

have remedied $7,304 in questioned costs. However, the questioned costs were remedied when OJP 

deobligated the funds.
13

officials agreed and implemented an internal process to review at least 10 percent 

of the claims for accuracy on a quarterly basis. As a result, we do not recommend 

any further action regarding secondary review of claims.

Administrative Expenditures

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

pay for administering its crime victim compensation program. However, such costs 

must derive from efforts to improve program effectiveness and service to crime 

victims, including claims processing, staff development and training, and public 

outreach.

For the compensation grant program, we tested the WCVCP’s compliance

with the 5 percent limit on the administrative expenses and found that WCVCP

complied with or is positioned to comply with the 5 percent administrative 

expenditure limitations. In addition to testing the WCVCP’s compliance with the 

5 percent administrative allowance, we also performed a detailed review of a

sample of these administrative expenditures. We judgmentally selected 

15 expenditures, totaling $22,843. Based on our testing, we found that the 

administrative expenditures charged by the WCVCP were both allowable and 

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 disbursements or 

reimbursements made immediately or within 10 days. VOCA victim compensation 

grant funds are available for the fiscal year of the award plus 3 additional fiscal 

years. To assess whether the WCVCP managed grant receipts in accordance with 

these federal requirements, we compared the total amount reimbursed to the total 

expenditures in the WCVCP’s accounting system and accompanying financial 

records.

For the VOCA victim compensation awards, we found that the WCVCP

calculated its drawdown funding requests to reimburse the state for compensation 

claims paid on behalf of the victim or to the victim, and the 5 percent 

administrative costs. Although our testing only covered through May 2019, Table 6

shows the total amount drawn down for each grant as of November 2019.
14

Table 6

Amount Drawn Down for Each Grant as of November 2019

Award Number Total Award Award Period 

End Date

Amount Drawn 

Down

Amount 

Remaininga

2015-VC-GX-0051 $683,000 09/30/2018 $683,000 $0

2016-VC-GX-0044 $714,000 09/30/2019 $709,436 $4,564

2017-VC-GX-0072 $473,000 09/30/2020 $451,363 $21,637

2018-V1-GX-0019 $548,000 09/30/2021 $45,391 $502,609

Total: $2,418,000 $1,889,190 $528,810

a According to the WCVCP, the amount remaining for grant 2016-VC-GX-0044 will be drawn down 

within 90 days from the award period end date.

Source: OJP

During this audit, we did not identify significant deficiencies related to the 

recipient’s process for developing drawdown requests.

Financial Reporting

According to the 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

WCVCP submitted accurate Federal Financial Reports (FFRs), we compared the FFRs 

to the WCVCP’s accounting records for each grant. We determined that the 

quarterly and cumulative expenditures for the reports reviewed matched the 

WCVCP’s accounting records.
15

CONCLUSION AND RECOMMENDATIONS

We found that the WCVCP used its VOCA funding to enhance its crime victim 

compensation program. However, we found that the WCVCP did not accurately 

calculate and report on its Crime Victim Compensation State Certification Forms the 

correct amount eligible for federal matching funds in FYs 2013 through 2017.

Because these reported amounts are the basis for future VOCA awards, the errors 

on the WCVCP’s forms resulted in excess awards totaling $822,000 for the FYs 2015

through 2019 grants. However, subsequent to the issuance of our draft report, OJP 

deobligated $26,000 in unallowable costs and $316,850 in funds to be put to better 

use. Therefore, we questioned the remaining $469,799 as unallowable, and $9,351 

as funds to be put to better use. Further, we found that WCVCP did not always 

obtain adequate documentation for claim payments, or perform secondary review of 

claims, resulting in errors calculating the claim reimbursement amounts. This

resulted in $16,345 in unsupported and $1,791 in unallowable expenditures 

charged to the grants, which OJP deobligated and adequately remedied subsequent 

to the issuance of our draft report. In addition, we found that the WCVCP was 

unable to support some of its performance data and did not retain its queries of 

data to support its reported performance metrics. We provide eight

recommendations to OJP to address these deficiencies.

We recommend that OJP:

1. Work with the WCVCP to update its policies and procedures to include details 

on processing victim payments.

2. Ensure the WCVCP develop written procedure for refunds.

3. Work with the WCVCP to remedy the remaining $469,799 of the $495,799 in 

excess grant funds awarded for FYs 2015 through 2017 grants.13

4. Work with the WCVCP to remedy the remaining $9,351 of the $326,201 in

funds to be put to better use for the FYs 2016 through 2019 grants.14

5. Work with the WCVCP to create policies or procedures to ensure that it 

maintains support for the performance data used at the time of reporting to 

OVC and thereby enable reconciliation of reported data with its internal 

records. 

6. Work with WCVCP to strengthen its current policies and procedures to ensure 

it obtains all necessary documentation to support any lost wage amount paid.

 13 As discussed previously, OJP deobligated $26,000 of the previously questioned excess 

grant funds. That amount is not included in the $469,799.

14 As discussed previously, OJP deobligated $316,850 of the previously questioned funds to 

be put to better use. That amount is not included in the $9,351. 
16

7. Remedy $16,345 in unsupported expenditures charged to the VOCA victim 

compensation program grants.15

8. Remedy $1,791 in unallowable expenditures charged to the VOCA victim 

compensation program grants.15

 15 As discussed previously, OJP deobligated the unsupported and unallowable expenditures that we identified in our 

audit. Based on the actions in its response to a draft of this report (see Appendix 3), OJP requested closure of 

Recommendations 7 and 8. These actions are sufficient to remedy the questioned costs, as explained more fully in Appendix 5. 
17

APPENDIX 1

OBJECTIVE, SCOPE, AND METHODOLOGY

Objective

The objective of the audit was to evaluate how Wyoming Crime Victim 

Compensation Program (WCVCP) designed and implemented its crime victim

compensation 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, and (3) grant 

financial management.

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 compensation

formula grants 2015-VC-GX-0051, 2016-VC-GX-0044, 2017-VC-GX-0072, and 

2018-V1-GX-0019 from the Crime Victims Fund (CVF) awarded to the WCVCP. The 

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

grants totaling $2,418,000 to the Wyoming Office of the Attorney General, which 

serves as the state administering agency. Our audit concentrated on, but was not 

limited to, the period of October 1, 2014, the project start date for VOCA 

compensation grant number 2015-VC-GX-0051, through December 2019. As of

November 2019, the WCVCP had drawn down a total of $1,889,190 from the four

audited grants.

To accomplish our objective, we tested compliance with what we consider to 

be the most important conditions of the WCVCP’s activities related to the audited 

grants. We performed sample-based audit testing for grant expenditures, which 

includes administrative and claim compensation costs, and progress reports. 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 compensation program 

guidelines, the DOJ Grants Financial Guide, state compensation criteria, 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 as well as the WCVCP 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 identified involving information from those 

systems was verified with documents from other sources.
18

While our audit did not assess WCVCP’s overall system of internal controls, 

we did review the internal controls of WCVCP’s financial management system 

specific to the management of funds for each VOCA grant within our review. To 

determine whether WCVCP adequately managed the VOCA funds we audited, we 

conducted interviews with state of Wyoming financial staff, examined policies and 

procedures, and reviewed grant documentation and financial records. We also 

developed an understanding of WCVCP’S financial management system and its 

policies and procedures to assess its risk of non-compliance with laws, regulations, 

guidelines, and terms and conditions of the grants.
19

APPENDIX 2

SCHEDULE OF DOLLAR-RELATED FINDINGS

Description Amount Pages

Questioned Costs:16

Excess FY 2015 Victim Compensation Award Expended $224,000 6, 13

Excess FY 2016 Victim Compensation Award Expended $173,436 6, 13

Excess FY 2017 Victim Compensation Award Expended $98,363 6, 13

Other Lost Wage Claims $341 11-12

Other Claims $1,450 12

Unallowable Costs $497,590

Other Lost Wage Claims $5,165 12

Other Claims $11,180 12

Unsupported Costs $16,345

Net Questioned Costs $513,935

Funds to be put to Better Use:17

Excess FY 2016 Victim Compensation Award Remaining14 $4,564 6, 13

Excess FY 2017 Victim Compensation Award Remaining18 $21,637 6, 13

Excess FY 2018 Victim Compensation Award Remaining $163,000 6, 13

Excess FY 2019 Victim Compensation Award Remaining $137,000 6

Total Funds to be put to Better Use $326,201

Less Remedied Costs19

Less Remedied Unallowable Costs $27,791

Less Remedied Unsupportable Costs $16,345

Less Remedied Funds to be put to Better Use $316,850

Total Remedied Costs ($360,986)

TOTAL DOLLAR-RELATED FINDINGS $479,150

 16 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.

17 Funds to be put to Better Use are future funds that could be used more efficiently if 

management took actions to implement and complete audit recommendations.

18 As shown in Table 6, as of November 2019, the WCVCP had not drawn down all funds for 

Award Numbers 2016-VC-GX-0044 and 2017-VC-GX-0072; as a result, we included these amounts as 

funds to be put to better use.

19 Prior to issuance of the final report, OJP deobligated $360,986 in previously questioned and 

funds to be put to better use that we identified during our audit. 
20

APPENDIX 3

U.S. DEPARTMENT OF JUSTICE OFFICE OF JUSTICE PROGRAMS 

RESPONSE TO THE DRAFT AUDIT REPORT20

 20 Attachments to this response were not included in this final report. 
21
22
23
24
25

APPENDIX 4

WYOMING OFFICE OF THE ATTORNEY GENERAL DIVISION OF 

VICTIM SERVICES RESPONSE TO THE DRAFT AUDIT REPORT21

 21 Attachments to this response were not included in this final report.
26
27
28
29
30
31
32

APPENDIX 5

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 Wyoming Office of the 

Attorney General and the Office of Justice Programs (OJP) for review and official 

comment. OJP’s response is incorporated in Appendix 3 of this final report, and the 

WCVCP’s response is incorporated in Appendix 4. OJP agreed with each 

recommendation contained in this report and discussed the actions it plans to 

complete in order to address the recommendations. As a result, the report is 

resolved. The WCVCP concurred with six recommendations, partially concurred

with one recommendation, and did not concur with one recommendation, as 

discussed below. The following provides the OIG analysis of the responses and 

summary of actions necessary to close the report.

Recommendations for OJP

1. Work with the WCVCP to update its policies and procedures to 

include details on processing victim payments.

Closed. The WCVCP concurred with our recommendation and included a 

revised policy with its response. The WCVCP stated that the Fiscal Section 

updated its policy to include detailed instructions on processing victim 

compensation payments.

OJP agreed with our recommendation. After receiving OJP’s and WCVCP’s

official responses to our draft report, we confirmed with OJP that it agreed 

that WCVCP’s updated policy includes details on processing victim payments,

and OJP requested closure of this recommendation.

We reviewed the revised policy included with the WCVCP’s response and 

found that the policy now includes detailed instructions on processing victim 

compensation payments. As a result, we consider this recommendation 

closed.

2. Ensure the WCVCP develop written procedure for refunds.

Closed. The WCVCP concurred with our recommendation and included a 

revised policy with its response. The WCVCP stated that the Fiscal Section 

has a written procedure for handling refunds. 

OJP agreed with our recommendation. After receiving OJP’s and WCVCP’s 

official response to the draft report, we confirmed with OJP that it agreed 

that WCVCP’s updated policy includes procedures for refunds and OJP 

requested closure of this recommendation.
33

We reviewed the policy included with the WCVCP’s response and found that 

the policy now includes a process for handling refunds. As a result, we 

consider this recommendation closed.

3. Work with the WCVCP to remedy the remaining $469,799 of the 

$495,799 in excess grant funds awarded for FYs 2015 through 2017 

grants.

Resolved. OJP agreed with our recommendation. OJP stated in its response

that, in February 2020, in accordance with instructions from the WCVCP,

OJP’s Office of the Chief Financial Officer deobligated $26,000 of the excess 

funds from Grant Number 2019-V1-GX-0003. As a result, OJP requested the 

closure of $26,000 in excess grant funds associated with this 

recommendation. Furthermore, in regards to the remaining $469,799 in 

excess grant funds, OJP will review these costs and work with the WCVCP to 

remedy, as appropriate.

The WCVCP also concurred with our recommendation. The WCVCP stated 

that it included a funding object code that should not have been attributed to 

the Crime Victim Compensation formula. WCVCP officials stated that the 

inclusion of the funding object code had initially occurred during the 

completion of the FY 2013 State Certification as a result of a change of staff. 

To remedy the recommendation, WCVCP proposes to revert funds from 

existing and future awards to offset the balance owed to OJP. Specifically, 

WCVCP stated that it will revert:

• $93,799 from its FY 2017 grant,22

• $263,0000 from its FY 2019 grant, and

• $139,000 from its FY 2020 grant.

Furthermore, although the WCVCP acknowledged that this funding code 

should not have been included when completing its state certification forms, 

they stated that they would like the opportunity to mitigate related 

questioned costs. The WCVCP provided a summary report for $254,018 

from the questioned funding object code that it believed qualified as 

expenditures that provided emergency financial assistance directly to victims 

and should have been included in the state certification forms. However, the 

summary report did not provide details on what the emergency financial 

assistance was paid for and whether that assistance went directly to a victim 

of crime.

Based on our review of the supporting documents provided by OJP, we

consider $26,000 in funds deobligated from Grant Number 

2019-V1-GX-0003 to have been appropriately remedied. Therefore, this

recommendation can be closed when we receive documentation that OJP has 

 22 As shown in Table 6, the $93,799 of funds WCVCP plans to deobligate from the FY 2017 

grant is more than what the grant balance is as of November 2019.
34

remedied the remaining $469,799 of the $495,799 in excess funds awarded 

for the FYs 2015 through 2017 grants.

4. Work with the WCVCP to remedy the remaining $9,351 of the 

$326,201 in funds to be put to better use for the FYs 2016 through 

2019 grants.

Resolved. OJP agreed with our recommendation. OJP stated in its response

that, in February 2020, OJP’s Office of the Chief Financial Officer deobligated 

$316,850 of the $326,201 in fund to be put to better use. Specifically, OJP’s 

Office of the Chief Financial Officer deobligated:

• $16,850 from Grant Number 2017-VC-GX-0072;

• $163,000 from Grant Number 2018-V1-GX-0019; and

• $137,000 from Grant Number 2019-V1-GX-0003.

As a result, OJP requested the closure of the $316,850 in funds to be put to 

better use associated with this recommendation.

The WCVCP also concurred with our recommendation. WCVCP officials stated 

that unexpended funds from its 2017, 2018, and 2019 grant awards will be 

returned to OVC immediately. Specifically, the WCVCP stated that it would

return:

• $26,201 in unexpended funds from its FY 2017 grant,23

• $163,000 in unexpended funds from its FY 2018 grant, and

• $137,000 in unexpended funds from its FY 2019 grant.

Based on our review of the supporting documents provided by OJP, we 

consider $316,850 in funds to be to better use to have been appropriately 

remedied. Therefore, this recommendation can be closed when we receive 

documentation that OJP has remedied the remaining $9,351 of the $362,201

in funds to be put to better use for the FYs 2016 through 2019 grants.

5. Work with the WCVCP to create policies or procedures to ensure that 

it maintains support for the performance data used at the time of 

reporting to OVC and thereby enable reconciliation of reported data 

with its internal records.

Closed. The WCVCP concurred with our recommendation and included a 

revised policy with its response. The WCVCP stated that it has adopted an 

internal policy that preserves the quarterly reports by saving copies of all 

reports generated.

OJP agreed with our recommendation. After receiving OJP’s and WCVCP’s 

official response to the draft report, we confirmed with OJP that it agreed 

 23 At the time of deobligation, the WCVCP had drawn $9,351 in funds from Grant Number 

2017-VC-GX-0072. As a result, OJP only deobligated $16,850 in funds remaining for this grant.
35

that WCVCP’s updated policy includes a process for maintaining support for 

the performance data used at the time of reporting and OJP requested 

closure of this recommendation. 

We reviewed the internal quarterly and annual performance report policy 

included in the WCVCP’s response and found that the policy now includes an 

adequate process for maintaining support for the performance data reported 

to OVC. As a result, we consider this recommendation closed.

6. Work with the WCVCP to strengthen its current policies and 

procedures to ensure it obtains all necessary documentation to 

support any lost wage amount paid.

Resolved. OJP agreed with our recommendation. OJP stated in its response

that it will coordinate with the WCVCP to obtain a copy of its written policies 

and procedures, developed and implemented, to ensure that necessary 

documentation is obtained to support lost wage amounts paid to crime 

victims.

The WCVCP also concurred with our recommendation but reserved the right 

to augment its lost wage policies and procedures to conform to OVC guidance 

while adopting some aspects of the OIG’s recommendation.

In its response, the WCVCP provided numerous reasons related to its 

decision to remove the physician or mental health service provider 

verification from its lost wage policies and procedures. However, as noted in 

the Grant Expenditures section of this report, we disagreed with WCVCP’s 

decision to remove the physician or mental health service provider 

verification. Further, the WCVCP ultimately concluded in its response, that it 

would augment its lost wage policy to reinstate the physician or mental 

health provider verification for any claim of lost wages that exceeds 30 days.

This recommendation can be closed when we receive the updated policies 

and procedures.

7. Remedy $16,345 in unsupported expenditures charged to the VOCA 

compensation program grants.

Closed. OJP agreed with our recommendation. OJP stated in its response 

that, in February 2020, OJP’s Office of the Chief Financial Officer deobligated 

$16,345 in unsupported expenditures charged to the VOCA victim 

compensation program grants, from Grant Number 2019-V1-GX-0003. As a 

result, OJP requested the closure of this recommendation. We consider this 

recommendation closed based on our review of the deobligation documents 

from OJP.

The WCVCP partially concurred with our recommendation. In its response, 

the WCVCP stated that of the $16,345 of unsupported expenditures, the 

WCVCP concurs that $6,267 should not have been billed to the VOCA 

compensation program grants and will correct the error by moving these
36

expenses to state funds. However, WCVCP did not concur with, and 

requested reconsideration of, the remaining $10,079 in costs associated with 

four unsupported expenditures. Based on our review of support that WCVCP 

provided with its response, we found that the WCVCP adequately supported 

two of the previously questioned expenditures of $3,906 and $3,057. While 

OJP has deobligated the amount of these two expenditures, we provide this 

determination for OJP’s consideration should WCVCP request reimbursement 

now that it can support these two expenditures. 

However, for the other two transactions, we found that the documentation 

provided did not support the expenditures charged to the VOCA 

compensation program grants. We provide our analysis for OJP’s 

consideration in remedying additional questioned costs in this report. 

Specifically:

1. According to the claim file, the victim received emergency medical 

treatment almost 2 months after the crime. As a result, the WCVCP

sent an official letter to the victim requesting additional support that 

the emergency medical care was directly related to the crime. The 

WCVCP provided a description of a diagnosis code that would support 

the victim being treated for anxiety disorder. However, there was no 

diagnosis code, but only the service provided. The WCVCP did not 

provide adequate documentation to support that the emergency 

medical treatments were a result of the crime, 2 months prior. As a 

result, we are still questioning the $2,854 as unsupported.

2. According to the claim file, the WCVCP paid $8,542 associated with the 

victim’s medical expenses in February 2019; however, the latest 

medical bill, dated in October 2018, showed medical expenses totaling 

$7,667. As a result, we are still questioning the difference of $262 as 

unsupported.24

8. Remedy $1,791 in unallowable expenditures charged to the VOCA 

compensation program grants.

Closed. OJP agreed with our recommendation. OJP stated in its response 

that, in February 2020, OJP’s Office of the Chief Financial Officer deobligated 

$1,792 from Grant Number 2019-V1-GX-0003 to account for these 

unallowable expenditures that WCVCP charged to the VOCA victim 

compensation program grants. As a result, OJP requested the closure of this 

recommendation. We consider this recommendation closed based on our 

review of the deobligation documents from OJP. 

The WCVCP did not concur with our recommendation. WCVCP officials 

requested that we consider reclassifying these costs as unsupported rather 

than unallowable. The following provides the OIG analysis of the WCVCP 

responses for each of the three expenditures:

 24 This transaction was paid with both federal and state funds. We only question $262, the 

portion of payment paid with federal funds.
37

1. The WCVCP believed this finding was caused by a misunderstanding of 

the Wyoming Victim Compensation Guidelines Policy due to the nuance 

of the formatting. WCVCP stated that the travel expenditure was for 

an associated victim and not a claimant’s family member. However, 

based on the documentation in the file, the travel expense was not for 

an associated victim to receive counseling or medical treatment. 

Rather, the expense was for a family member to visit the victim. 

Therefore, we stand by our conclusion that the expense in excess of 

the financial limit by $600 is unallowable.

2. The WCVCP stated in its response that it made the payment to a livein girlfriend of the victim, and while the Wyoming Victim Compensation 

Guidelines Policy is not specific, it seems natural that two adults, 

cohabitating as if married, can be viewed as “family” to one another. 

However, based on the claimant’s file, there was no support that the 

victim lived with the girlfriend. Therefore, we stand by our conclusion

to question the expense, totaling $850.

3. Finally, the WCVCP stated in its response that the Wyoming Victim 

Compensation Guidelines Policy is silent on bereavement leave, but it 

has been the office’s practice to compensate victims for that type of 

leave. WCVCP stated it will amend the Wyoming Victim Compensation 

Guidelines Policy to specifically include bereavement. Therefore, since 

WCVCP will amend the policy to include bereavement, we can consider 

the allowability of this expenditure should OJP determine that WCVCP’s 

updated policy is sufficient to address our finding and

recommendation.

While this recommendation is closed based on OJP’s deobligation decision, 

we provided our analysis of WCVCP’s response to our draft report for OJP to

consider should WCVCP request OJP to reconsider its deobligation decisions, 

and in remedying additional questioned costs in this report.
U.S. DEPARTMENT OF JUSTICE OFFICE OF THE INSPECTOR GENERAL

950 Pennsylvania Avenue, NW

Washington, DC 20530-0001 

Also at Oversight.gov

The Department of Justice Office of the Inspector General (DOJ OIG) is a 

statutorily created independent entity whose mission is to detect and deter 

waste, fraud, abuse, and misconduct in the Department of Justice, and to 

promote economy and efficiency in the Department’s operations.

To report allegations of waste, fraud, abuse, or misconduct regarding DOJ 

programs, employees, contractors, grants, or contracts please visit or call the

DOJ OIG Hotline at oig.justice.gov/hotline or (800) 869-4499.

Website Twitter YouTube

oig.justice.gov @JusticeOIG JusticeOIG

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