Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Office of Justice Programs 

Cooperative Agreements Awarded 

to the Colorado Organization for 

Victim Assistance,

Denver, Colorado

REDACTED FOR PUBLIC RELEASE

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 3, the grantee’s response, and are of individuals’ names.

Audit Division 20-066 May 2020

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS

COOPERATIVE AGREEMENTS AWARDED TO

THE COLORADO ORGANIZATION FOR VICTIM ASSISTANCE, 

DENVER, COLORADO

TABLE OF CONTENTS

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

The Awardee ..................................................................................... 1

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

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

Program Performance and Accomplishments ........................................... 3

Program Goals and Objectives ..................................................... 3

Required Performance Reports..................................................... 3

Compliance with Special Conditions .............................................. 5

Award Financial Management ............................................................... 6

Award Expenditures ............................................................................ 6

Personnel Costs......................................................................... 7

Contractor Costs........................................................................ 8

Other Direct Costs ..................................................................... 9

Indirect Costs ......................................................................... 10

Matching Costs........................................................................ 11

Budget Management and Control ........................................................ 12

Drawdowns ..................................................................................... 12

Federal Financial Reports ................................................................... 13

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

APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY ................................ 16

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS............................... 18

APPENDIX 3: COLORADO ORGANIZATION FOR VICTIM ASSISTANCE’S 

RESPONSE TO THE DRAFT AUDIT REPORT............................................ 19
APPENDIX 4: OFFICE OF JUSTICE PROGRAMS’ RESPONSE TO THE DRAFT 

AUDIT REPORT................................................................................. 29

APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF THE ACTIONS NECESSARY TO CLOSE THE REPORT ........................... 34

2 

coordinated case management with other programs, depending on what is best for 

the individual client.1

OIG Audit Approach

The objectives of this audit were to determine whether costs claimed under 

the awards were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the award; and to determine 

whether the awardee demonstrated adequate progress towards achieving the 

program goals and objectives. To accomplish these objectives, we assessed 

performance in the following areas of award management: program performance, 

financial management, expenditures, budget management and control, drawdowns, 

and federal financial reports.

We tested compliance with what we consider to be the most important 

conditions of the awards. The 2015 and 2017 DOJ Grants Financial Guides and the 

award documents contain the primary criteria we applied during the audit.

The results of our analysis are discussed in detail later in this report. 

Appendix 1 contains additional information on this audit’s objectives, scope, and 

methodology. The Schedule of Dollar-Related Findings appears in Appendix 2.

1 Background information on COVA has been taken from the organization’s website directly 

(unaudited).
3 

AUDIT RESULTS

Program Performance and Accomplishments

We reviewed required performance reports, award documentation, and 

interviewed recipient officials to determine whether COVA demonstrated adequate 

progress towards achieving the program goals and objectives. We also reviewed 

the progress reports to determine if the required reports were accurate. Finally, we 

reviewed COVA’s compliance with the special conditions identified in the award 

documentation.

Program Goals and Objectives

For Award Numbers 2015-VT-BX-K050 and 2018-VT-BX-K036, the goals and

objectives for each award included: (1) identify victims of sex trafficking and labor 

trafficking in the State of Colorado and offer intensive, client-driven case management;

(2) collaborate, as appropriate, with law enforcement, local service providers, and 

nonprofit and faith-based organizations to ensure that victims of human trafficking 

are identified and referred to for appropriate resources; (3) conduct training, public 

awareness, and outreach activities statewide; and (4) conduct data collection and 

action research activities and evaluation activities to determine if the program is 

meeting stated goals and objectives.

Based on our review, there were no indications that COVA was not 

adequately achieving the stated goals and objectives of the awards. 

Required Performance Reports

According to the DOJ Grants Financial Guide, the funding recipient should 

ensure that valid and auditable source documentation is available to support all 

data collected for each performance measure specified in the program solicitation. 

In order to verify the information in progress reports, we selected a sample of 

5 performance measures from the 2 most recent reports submitted for award 

2015-VT-BX-K050 and 5 performance measures from the most recent report 

submitted for award 2018-VT-BX-K036 for a total sample size of 15.2 We then 

traced the items to supporting documentation maintained by COVA. 

Based on our review, we found that the progress reports we tested were 

generally inaccurate or not supported. COVA uses the Trafficking Information 

Management System (TIMS) to track progress report data related to client services 

and referrals for assistance; technical assistance and training activities; the number 

of partner organizations; and community outreach and public awareness activities.3 

2 At the time of our review, only two progress reports had been submitted for Award Number

2018-VT-BX-K036 and no activity was reported on the first progress report.

3 TIMS is designed to assist the OJP Office for Victims of Crime (OVC) Human Trafficking 

awardees in gathering, recording, analyzing, and reporting required performance measures. This tool 

serves as a central repository of information related to all activities under the OVC human trafficking 

cooperative agreement initiative and enables OVC awardees to organize, standardize, and centralize 

data collection efforts on a wide variety of core performance measures. 
4 

For the performance measures we tested related to these activities, COVA provided 

TIMS reports. In order to verify the reliability of the TIMS data, we selected a 

judgmental sample of client information and services from the periods included in 

our analysis. We then traced the sample to supporting documentation maintained 

by COVA. Based on our review, we found that COVA could not provide adequate 

documentation to support client services. We also noted the TIMS data related to 

client information was not always accurate. As a result, we determined that we 

could not rely on the progress report information provided from TIMS; therefore, 

we could not verify the accuracy of the performance measures that were based on 

TIMS data. Our concerns related to the accuracy of the TIMS data were confirmed 

by COVA’s Chief Deputy Director, who stated during our interviews that the data in 

TIMS may not be accurate. COVA’s Chief Deputy Director also expressed concerns 

related to the accuracy of the information included in the progress reports for the 

Award Number 2015-VT-BX-K050. Our analysis of the accuracy of the progress 

report performance measures we tested for each award is summarized below.

• Award Number 2015-VT-BX-K050: For Report Number 6, we determined 

that none of the five performance measures tested were adequately 

supported. We were unable to verify the accuracy of the TIMS data related 

to the number of partner organizations, awareness presentations, other 

services, total number of trainings conducted, and new client cases closed 

reported. We also noted that the TIMS data related to the number of partner 

organizations included paid vendors such as Lyft, Uber, and United Airlines. 

According to COVA officials, they believe prior human trafficking employees 

erroneously entered all outside organizations into TIMS, regardless of 

whether the services were provided by partner organizations or paid vendors. 

As a result, for performance measures related to partner organizations, 

COVA also overstated the numbers reported. In addition to the TIMS data, 

COVA provided summary documentation to support the number of total 

trainings conducted and the number of awareness presentations reported. 

However, COVA could not provide documentation supporting the summary 

report data; as a result, we could not verify the accuracy of the numbers 

reported. For Report Number 7, we determined that none of the five 

performance measures tested were adequately supported. We were unable 

to verify the accuracy of the TIMS data related to the number of community 

outreach activities, direct and street outreach activities, trafficking victims 

served, new client cases and total number of trainings conducted reported. 

In addition to the TIMS data, COVA provided summary documentation to 

support the number of total trainings conducted and the number of direct 

and street outreach activities reported. However, COVA could not provide 

documentation supporting the summary report data; as a result, we could 

not verify the accuracy of the numbers reported.

• Award Number 2018-VT-BX-K036: For Report Number 2, we determined 

that none of the five performance measures tested were adequately 

supported. For four performance measures, we were unable to verify the 
5 

accuracy of the TIMS data related to the number of community outreach 

activities reported and the number of trafficking victims served reported. For 

one performance measure COVA provided summary documentation to 

support the total financial assistance provided to trafficking clients. However,

COVA could not provide documentation supporting all the summary report 

data; as a result, we could not verify the accuracy of the numbers reported.

Based on our analysis we found that the progress reports we tested were 

inaccurate or not adequately supported. Therefore, we recommend that OJP 

coordinate with COVA to ensure that progress reports are accurate and fully 

supported.

Compliance with Special Conditions

Special conditions are the terms and conditions that are included with the 

awards. We evaluated the special conditions for each award and selected a 

judgmental sample of four requirements that are significant to performance under 

the awards and are not addressed in another section of this report. We evaluated 

special conditions that required additional or revised plans and policies or ongoing 

communication with state and federal stakeholders.

Based on our review, we found that COVA was not in compliance with the 

four special conditions we tested. Specifically, we found that COVA was not in 

compliance with the following special conditions. Number 40 for Award Number

2015-VT-BX-K050 and Number 43 for Award Number 2018-VT-BX-K036, requiring 

that the awardee submit to the Office of Victims of Crime (OVC), within 30 days of 

the award, a revised time-task plan. We also found that COVA was not in 

compliance with special condition 54 for award 2015-VT-BX-K050, requiring that 

the awardee notify the State Victims of Crime Act (VOCA) Assistance and 

Compensation program administrators and appropriate United States Attorney’s 

Victim Witness Coordinators of all training events that will be held in their states as 

a result of this award. Additionally, we found that COVA was not in compliance with 

special condition Number 50 for award 2018-VT-BX-K036, requiring that the 

awardee submit to OVC, within 90 days of the date of award, for review and 

approval, its policies and procedures that it has established to maintain the 

confidentiality of victims' names, addresses, telephone numbers, or any other 

identifying information, and its policies and procedures relating to information 

sharing between partners. Finally, although not included in our sample, we found 

that COVA was not in compliance with special condition Number 57 for Award 

Number 2018-VT-BX-K036, requiring that the recipient may not obligate, expend or 

draw down funds until the Office of the Chief Financial Officer has approved the 

budget and budget narrative and a Grant Adjustment Notice (GAN) has been issued 

to remove this special condition. Therefore, we recommend that OJP coordinate 

with COVA to develop policies and procedures that ensure it adheres to all special 

conditions for the awards.
6 

Award Financial Management

According to the DOJ Grants Financial Guide, all award recipients are 

required to establish and maintain adequate accounting systems and financial 

records, and to accurately account for funds awarded to them. To assess COVA’s 

financial management of the awards covered by this audit, we conducted interviews 

with COVA program and financial staff, examined COVA’s policies and procedures, 

and reviewed award documents to determine whether COVA adequately safeguards 

the award funds we audited. We also reviewed COVA’s Single Audit Report for the 

fiscal year ending June 2018 to identify internal control weaknesses and significant 

non-compliance issues related to federal awards. Finally, we performed testing in 

the areas that were relevant for the management of the awards, as discussed 

throughout this report.

Based on our analysis, we identified weaknesses in COVA’s financial 

management that resulted in unallowable and unsupported questioned costs 

totaling $477,941. Specifically, we found that COVA: (1) charged unallowable and 

unsupported costs to the awards; (2) did not maintain adequate documentation to 

support the required matching costs for the awards; and (3) submitted FFRs that 

were inaccurate. These deficiencies are discussed in more detail in the Payroll 

Costs, Other Direct Costs, Indirect Costs, Matching Costs, and Federal Financial 

Reports Sections of this report. 

Additionally, we found that COVA’s written policies and procedures could be 

strengthened. We found that COVA’s policies and procedures do not clearly define 

separation of duties. We also noted that COVA’s policies and procedures did not 

have specific language regarding procurement, verifying that its vendors are not 

debarred or suspended from doing business with the federal government, approving 

and paying expenditures, matching costs, indirect costs, or performance 

measurement and outcome assessment. Therefore, we recommend that OJP 

coordinate with COVA to ensure it develops and implements new policies and 

procedures that include specific language regarding separation of duties, 

procurement, verifying that its vendors are not debarred or suspended from doing 

business with the federal government, approving and paying expenditures, 

matching costs, indirect costs, and performance measurement and outcome 

assessment.

Award Expenditures

For the awards in our scope, COVA’s approved budgets included personnel, 

fringe benefits, travel, supplies, contractual, subrecipient, other direct, and indirect

costs. In addition, COVA was required to provide a total of $558,333 in local 

matching funds, which represents a 25 percent local match.4 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. Our 

4 Throughout this report, differences in the total amounts are due to rounding. The sum of 

individual numbers prior to rounding may differ from the sum of the individual numbers rounded.
7 

sample included 526 transactions, totaling $348,316.5 We also tested all matching 

costs for the awards.6 We reviewed documentation, accounting records, and 

performed verification testing related to award expenditures. As discussed in the 

following sections, we identified $477,941 in questioned costs, including $10,161 in 

unallowable questioned costs and $467,780 in unsupported questioned costs.7

Personnel Costs

As part of our initial sample, we reviewed 34 payroll transactions totaling 

$56,852, which included all salary expenditures for 3 non-consecutive pay periods 

for each award in our scope. Additionally, COVA charged fringe benefits to the 

awards on a quarterly basis and accounted for fringe benefit costs on a separate 

spreadsheet, rather than the general ledgers for the awards. As a result, we 

selected a sample of fringe benefit transactions for 5 quarters. We reviewed our 

sample payroll transactions to determine if labor charges were computed correctly, 

properly authorized, accurately recorded, and properly allocated to the award. 

Based on our analysis, we identified $18,258 in total questioned costs, including 

$12,418 in unsupported personnel costs and $5,840 in unallowable personnel costs 

charged to Award Numbers 2015-VT-BX-K050 and 2018-VT-BX-K036. 

For Award Numbers 2015-VT-BX-K050 and 2018-VT-BX-K036, we found that 

COVA was not using the actual time recorded on the timesheets to allocate salary 

costs for the Chief Deputy Director to the awards, instead they used a flat 

percentage every pay period. As a result, we expanded our sample to include all

the Chief Deputy Director’s salary costs charged to the awards for all pay periods in 

2017. Based on our analysis, we determined that on average the questioned costs 

related to this issue were immaterial. However, the DOJ Grants Financial Guide 

requires that salaries allocated to federal awards should be based on actual time 

and effort reports, e.g., timesheets, that document hours worked by cost activity. 

Therefore, we recommend OJP coordinate with COVA to ensure that all personnel 

costs charged to the awards are based on actual time and effort.

For Award Number 2018-VT-BX-K036, we identified one position, the Human 

Trafficking Program intern that was not authorized in the approved budget. As a 

result, we expanded our analysis to include all salaries charged to the award for the

unauthorized position, resulting in $5,027 in unallowable questioned costs. We also 

found that for Award Number 2015-VT-BX-K050 COVA charged year-end bonuses 

for three employees to the award. However, bonuses were not included in the 

approved budget, resulting in $813 in unallowable questioned costs. Additionally, 

for Award Number 2018-VT-BX-K036, COVA obligated payroll expenditures to the 

5 Our sample included 79 monthly credit card transactions from the general ledgers for the 

awards, which were comprised of 575 individual charges from the monthly credit card statements.

6 COVA did not include matching costs in the general ledgers for the award and did not 

maintain any supplemental accounting records documenting individual matching cost transactions for 

the awards. Therefore, we requested and reviewed all supporting documentation for the matching 

costs.

7 The total questioned costs of $477,941 includes $37,395 in duplicate unsupported 

questioned costs, resulting in net questioned costs of $440,546, as shown in Appendix 2 of this report.
8 

award prior to complying with special condition Number 57, which states that the 

recipient may not obligate, expend or draw down funds until a GAN has been issued 

to remove this special condition. This issue is discussed in more detail in the 

Compliance with Special Conditions section of this report.

COVA did not account for fringe benefit costs in the general ledgers for the 

awards. Instead, COVA charged fringe benefits to the awards on a quarterly basis 

using a separate spreadsheet. According to the DOJ Grants Financial Guide, award 

recipients must have a financial management system in place that is able to record 

and report on the receipt, obligation, and expenditure of award funds, keeping 

detailed accounting records and documentation to track award expenditures. 

Therefore, we recommend that OJP ensure that COVA include all award-related 

expenditures in its general ledgers for the awards. 

Additionally, based on our analysis, we found that the fringe costs we tested 

were incorrectly computed and allocated to the awards. Specifically, we found

fringe benefits charged to the awards were not based on actual costs, instead COVA 

used 24 percent of the employees’ salaries that were allocated to the awards. 

Based on our analysis, we found that actual fringe benefit costs were less than the 

amounts charged to the awards, resulting in $12,418 in unsupported questioned 

costs. Additionally, we found that all employee retirement fund contributions were 

unsupported. Based on the supporting documentation, the employees were paying 

for their retirement fund contributions out of their own salaries. According to the 

COVA’s Executive Director, rather than paying the costs associated with retirement 

fund contributions directly, COVA paid the employees a higher salary and then 

deducted the retirement contributions from the employees pay. However, since 

there was no documentation to support this statement and the retirement 

contributions were made from the employee’s salary, we consider all retirement 

fringe benefits charged to the awards as unsupported. Because COVA did not 

maintain adequate accounting records detailing the fringe benefit costs charged to 

the awards, we were unable to determine the total unsupported questioned costs 

associated with this issue.

In total, we identified $12,418 in unsupported and $5,840 in unallowable 

personnel costs charged to the awards. Therefore, we recommend that OJP remedy 

the $12,418 in unsupported and $5,840 in unallowable personnel costs. 

Contractor Costs

As part of our sample, we reviewed one contractor transaction for award 

Number 2015-VT-BX-K050 totaling $7,096 to determine if charges were computed 

correctly, properly authorized, accurately recorded, and properly allocated to the 

awards.8 In addition, we determined if rates, services, and total costs were in 

accordance with those allowed in the approved budgets. Based on our review, we 

did not identify any issues related to contractor costs. 

8 There were no contractor costs for Award Number 2018-VT-BX-K036. 
9 

Other Direct Costs

As part of our sample, we reviewed 450 other direct cost transactions, 

totaling $248,397 to determine if charges were computed correctly, properly 

authorized, accurately recorded, and properly allocated to the award. Based on our 

review, we identified $197,068 in questioned costs, including $195,535 in 

unsupported costs and $1,533 in unallowable other direct costs charged to Award 

Numbers 2015-VT-BX-K050 and 2018-VT-BX-K036. 

For Award Number 2015-VT-BX-K050, we identified 412 transactions totaling 

$171,727 that were not supported and 4 transactions totaling $1,472 that were not 

allowable. Specifically, we identified the following unallowable and unsupported 

questioned costs.

• Our initial sample included 13 credit card transactions that were not 

supported. As a result, we expanded our analysis to include all 70 monthly 

credit card transactions from the general ledger, which were comprised of 

521 individual charges from the monthly credit card statements. Based on 

our analysis, we identified $55,326 in unsupported questioned costs, which 

included: (1) 189 transactions totaling $53,894, for which COVA was unable 

to provide any supporting documentation; (2) 1 transaction for long distance 

bus travel, for which COVA only provided a copy of an email stating that the 

trip was booked, which did not include the date or amount of the fare, only a 

handwritten note on it stating the date and amount, resulting in $205 in 

unsupported questioned costs; (3) 2 transactions for hotel stays for clients, 

for which COVA only provided copies of emails with the reservations, in which 

the reservation cost did not match the amounts charged, resulting in $695 in 

unsupported questioned costs; (4) 3 credit card monthly transactions for 

which the individual charges on the monthly statement did not add up to the 

amount charged to the award, resulting in $533 in unsupported questioned 

costs. Additionally, we identified $29 in unallowable questioned costs for a 

team meal, which was not included in the approved budget.

• Our initial transaction sample for Award Number 2015-VT-BX-K050 included 

two rental assistance transactions that were supported; however, given the 

issues we identified related to rental assistance for Award Number

2018-VT-BX-K036, we expanded our sample to included 283 rental

assistance transactions. Based on our analysis, we identified $49,154 in 

unsupported questioned costs, which included 188 transactions totaling 

$48,619 for which COVA was unable to provide any supporting 

documentation; and 1 transaction totaling $535 for which the supporting 

documentation provided by COVA did identify the client receiving assistance, 

and the rental agreement was missing the property address, the monthly 

rent, the amount that COVA agreed to contribute towards the rent, and the 

client’s signature.

• Three unallowable information technology services transactions totaling 

$1,444 that were not included in the approved budget.
10

• One transaction for costs associated with client services totaling $270, 

including transportation and lodging, for which COVA was unable to provide 

supporting documentation. 

• One transaction for a reimbursement request submitted by a COVA employee 

for client services totaling $374, for which COVA was unable to provide 

supporting documentation. 

• We also found that COVA purchased gift cards for client financial assistance. 

However, COVA could not provide any documentation to support that the gift 

cards were given to human trafficking clients or any documentation detailing 

the purchases made using the gift cards, resulting in $66,603 in unsupported 

questioned costs. 

For Award Number 2018-VT-BX-K036, we identified 64 transactions totaling 

$23,807 that were not supported and 1 transaction totaling $61 that was not allowable. 

Specifically, we identified the following unallowable and unsupported questioned costs.

• Our initial sample included seven credit card transactions that were not 

supported. As a result, we expanded our analysis to include all nine monthly 

credit card transactions from the general ledger, which were comprised of 54

individual charges from the monthly credit card statements. Based on our

analysis, we identified $3,646 in unsupported questioned costs, which 

included: (1) 9 transactions totaling $3,561, for which COVA was unable to 

provide any supporting documentation; (2) 1 credit card monthly transaction 

for which the individual charges on the monthly statement did not add up to 

the amount charged to the award, resulting in $85 in unsupported 

questioned costs. Additionally, we identified $61 in unallowable questioned 

costs for a team meal, which was not included in the approved budget.

• Our initial transaction sample included five rental assistance transactions that 

were not supported. As a result, we expanded our analysis to include all

64 rental assistance transactions from the general ledger. Based on our analysis,

we identified $9,641 in unsupported questioned costs related to 44 transactions

for which COVA was unable to provide any supporting documentation.

• One transaction for a partial payment made to a COVA credit card for 

employee travel, for which COVA was unable to provide documentation to 

support travel costs, resulting in $201 in unsupported questioned costs.

• We also found that COVA purchased gift cards for client financial assistance. 

However, COVA could not provide any documentation to support that the gift 

cards were given to human trafficking clients or any documentation detailing 

the purchases made using the gift cards, resulting in $10,320 in unsupported 

questioned costs. 

In total, we identified $195,535 in unsupported questioned costs and $1,533 

in unallowable questioned costs for items that were not included in the approved 

award budgets. Therefore, we recommend that OJP remedy the $195,535 in 

unsupported and $1,533 in unallowable other direct costs.

Indirect Costs
11

Indirect costs are costs of an organization that are not readily assignable to a 

particular project but are necessary to the operation of the organization and the 

performance of the project. We noted that indirect costs were included in the 

budget for Award Number 2018-VT-BX-K036. We selected the two indirect cost 

charges for Award Number 2018-VT-BX-K036.

Based on our analysis, we found that the indirect costs charged to Award 

Number 2018-VT-BX-K036 were generally supported. 

Matching Costs

Matching costs are the non-federal recipient’s share of the total project costs. 

These costs include cash spent for project-related costs and in-kind costs for 

services, supplies, real property, and equipment. The DOJ Grants Financial Guide 

requires recipients to maintain records that clearly show the source, amount, and 

timing for all matched contributions. The Financial Guide also states that 

documentation supporting the market value of in-kind match must be maintained in 

the award recipient files.

COVA’s required match was $250,000 for Award Number 2015-VT-BX-K050 

and $308,333 for 2018-VT-BX-K036. COVA used salaries and fringe benefits of 

non-award funded employees and in-kind volunteer services in order to meet its 

matching requirements. We found that COVA did not track matching transactions 

in its accounting records for the awards or on an electronic spreadsheet. Instead 

COVA maintained an electronic spreadsheet showing total matching costs for each 

quarter. As a result, we had to use COVA’s supporting documentation in order to 

identify the matching cost transactions for each award. We also reviewed the 

supporting documentation provided by COVA to determine if the costs were in 

accordance with matching requirements, properly supported, computed correctly, 

authorized, and accurately reported. Based on our review, we identified $259,827 

in unsupported matching questioned costs and $2,788 in unallowable matching 

questioned costs Award Numbers Award Numbers 2015-VT-BX-K050 and 

2018-VT-BX-K036. 

For Award Number 2015-VT-BX-K050, we identified $250,000 in unsupported 

matching costs. Based on the matching cost documentation provided by COVA, 

matching costs for the award totaled $181,607, which is $68,393 less than the 

required match. COVA did not provide any supporting documentation for the 

remaining $68,393 in reported matching costs. Additionally, we found that the

$181,607 in total matching costs for the award was not properly supported. 

Specifically, we found that for matching costs related to trainings, the only 

supporting documentation was a list of trainings that COVA either attended or 

provided, the number of attendees, and the number of training hours. COVA did 

not provide sign-in sheets to support the number of attendees, agendas to support 

the number of training hours and if the training was in support of the program 

goals, or documentation supporting attendee pay rates used to calculate the in-kind 

matching costs for services.
12

For Award Number 2018-VT-BX-K036, we identified $2,788 in unallowable 

matching costs and $9,827 in unsupported matching costs. Specifically, we

identified $2,788 in unallowable matching costs for the Executive Director’s salary 

that was not in the approved budget. In addition, we found that COVA incorrectly 

calculated the Executive Director’s wages that were allocated to the matching costs 

for the award, resulting in $114 in unsupported matching costs. COVA Officials 

were unable to provide supporting documentation for the reported matching costs 

for the quarter ending June 30, 2019, resulting in $9,713 in unsupported matching 

costs. Finally based on our analysis of the matching documentation, matching 

costs for the award as of June 30, 2019, totaled $0 which is $308,333 less than the 

required match. We are not questioning the $308,333 as unsupported because the 

award is still open. As a result, COVA has until September 30, 2021, to meet the 

match requirement for the award. However, based on the inadequate 

documentation provided and the fact that COVA did not meet the match 

requirement for Award Number 2015-VT-BX-K050, we are not confident it will meet 

its match requirement for this award.

In total, we identified $259,827 in unsupported and $2,788 in unallowable 

matching questioned costs claimed for the awards. As a result, we recommend OJP 

coordinate with COVA to remedy the $259,827 in unsupported and the $2,788 in 

unallowable matching costs. In addition, we recommend OJP ensure COVA meets

its matching requirements, tracks all matching transactions on its general ledgers, 

and implements new policies and procedures to ensure matching costs are properly 

supported.

Budget Management and Control

According to the DOJ Grants Financial Guide, the recipient is responsible for 

establishing and maintaining an adequate accounting system, which includes the 

ability to compare actual expenditures or outlays with budgeted amounts for each 

award. Additionally, the award recipient must initiate a GAN for a budget 

modification that reallocates funds among budget categories if the proposed 

cumulative change is greater than 10 percent of the total award amount.

We compared award expenditures to the approved budgets to determine 

whether COVA transferred funds among budget categories in excess of 10 percent. 

We determined that the cumulative difference between category expenditures and 

approved budget category totals was not greater than 10 percent for any of the 

awards we tested. 

Drawdowns

According to the DOJ Grants Financial Guide, an adequate accounting system 

should be established to maintain documentation to support all receipts of federal 

funds. If, at the end of the award period, recipients have drawn down funds in 

excess of federal expenditures, unused funds must be returned to the awarding 

agency. As of September 5, 2019, COVA had drawn down $779,259 from the 

awards included in our audit. To assess whether COVA managed award receipts in 

14

FFR for the award by $9,713. Therefore, we recommend OJP coordinate with COVA

to ensure that it submits accurate FFRs.

COVA officials concurred that the FFRs did not match its accounting records 

for the awards. COVA officials explained they used the general ledgers for the 

awards to prepare the FFRs; however, since fringe benefit costs were not recorded 

in the general ledgers, when preparing the FFRs, they used estimated fringe benefit

costs.
15

CONCLUSION AND RECOMMENDATIONS

As a result of our audit testing, we found that COVA demonstrated adequate 

progress towards achieving the awards’ stated goals and objectives. Additionally, 

we did not identify significant issues regarding COVA’s management of the award 

budgets or drawdowns. However, we found that COVA did not comply with 

essential award conditions related to progress reports, compliance with award 

special conditions, internal controls, use of award funds, matching funds, and FFRs. 

We provide 11 recommendations to OJP to address these deficiencies.

We recommend that OJP: 

1. Coordinate with COVA to ensure that progress reports are accurate and fully 

supported.

2. Coordinate with COVA to develop policies and procedures to ensure it 

adheres to all special conditions of the awards.

3. Coordinate with COVA to ensure it develops and implements new policies and 

procedures that include specific language regarding separation of duties, 

procurement, verifying that its vendors are not debarred or suspended from 

doing business with the federal government, approving and paying 

expenditures, matching costs, indirect costs, and performance measurement 

and outcome assessment. 

4. Coordinate with COVA to ensure that all personnel costs charged to the 

awards are based on actual time and effort.

5. Ensure that COVA include all award-related expenditures in its general 

ledgers for the awards. 

6. Remedy the $7,373 in unallowable questioned costs related to the $5,840 in 

unallowable personnel costs and $1,533 in unallowable other direct costs. 

7. Remedy the $207,953 in unsupported questioned costs related to the 

$12,418 in unsupported personnel costs and $195,535 in unsupported other 

direct costs. 

8. Remedy the $2,788 in unallowable matching funds.

9. Remedy the $259,827 in unsupported matching costs.

10. Coordinate with COVA to ensure it meets its matching requirements, tracks 

all matching transactions on its general ledgers, and implements new policies 

and procedures to ensure matching costs are properly supported.

11. Coordinate with COVA to ensure it submits accurate FFRs.
16

APPENDIX 1

OBJECTIVES, SCOPE, AND METHODOLOGY

Objectives

The objectives of this audit were to determine whether costs claimed under 

the awards were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions of the awards; and to determine 

whether the awardee demonstrated adequate progress towards achieving the 

program goals and objectives. To accomplish these objectives, we assessed

performance in the following areas of award management: program performance, 

financial management, expenditures, budget management and control, drawdowns, 

and federal financial reports.

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 objectives. We believe 

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

conclusions based on our audit objectives. 

This was an audit of the Office of Justice Programs (OJP) cooperative 

agreements awarded to the Colorado Organization for Victim Assistance (COVA) 

under the Comprehensive Services for Victims of Human Trafficking Program. OJP

awarded $750,000 through Award Number 2015-VT-BX-K050 and $925,000 

through Award Number 2018-VT-BX-K036, and as of September 5, 2019, had 

drawn down $779,259 of the total funds awarded. Our audit concentrated on, but 

was not limited to September 24, 2015, the award date for Award Number 

2015-VT-BX-K050, through January 2020, the last day of our audit work. We also 

noted that Award Number 2015-VT-BX-K050 had reached its project end date and 

was closed prior to the start of our audit.

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

be the most important conditions of COVA’s activities related to the audited awards. 

We performed sample-based audit testing for award expenditures, including payroll 

and fringe benefit charges; as well as matching costs; indirect costs; financial 

reports; and progress reports. In this effort, we employed a judgmental sampling 

design to obtain broad exposure to numerous facets of the awards reviewed. This 

non-statistical sample design did not allow projection of the test results to the 

universe from which the samples were selected. The 2015 and 2017 DOJ Grants 

Financial Guides 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 COVA’s accounting system specific to the management of award 

funds during the audit period. We did not test the reliability of those systems as a 

18

APPENDIX 2

SCHEDULE OF DOLLAR-RELATED FINDINGS

Description Amount Page

Questioned Costs:11

Unallowable Costs

Personnel Costs $5,840 9

Other Direct Costs $1,533 11

Matching Funds $2,788 12

Total Unallowable Costs $10,161

Unsupported Costs

Personnel Costs $12,418 9

Other Direct Costs $195,535 11

Matching Funds $259,827 12

Total Unsupported Costs $467,780

Gross Questioned Costs $477,941

Less Duplicate Questioned Costs12 ($37,395)

Net Questioned Costs $440,546

11 Questioned Costs are expenditures that do not comply with legal, regulatory, or 

contractual requirements, or 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, or the provision of supporting documentation.

12 Some costs were questioned for more than one reason. Net questioned costs exclude the 

duplicated amounts, which includes $37,281 in costs associated with the unsupported purchase of the 

gift cards, as well as the unsupported use of the gift cards; and $114 matching costs that were both 

unallowable and unsupported.
19

APPENDIX 3

COLORADO ORGANIZATION FOR VICTIM ASSISTANCE’S 

RESPONSE TO THE DRAFT AUDIT REPORT
20
21
22


25
26
27
28
29

APPENDIX 4 

OFFICE OF JUSTICE PROGRAMS’

RESPONSE TO THE DRAFT AUDIT REPORT
30
31
32
33
34

APPENDIX 5 

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND

SUMMARY OF THE ACTIONS NECESSARY TO CLOSE THE REPORT

The OIG provided a draft of this audit report to the Colorado Organization for 

Victim Assistance (COVA) and the Office of Justice Programs (OJP). COVA’s 

response is incorporated in Appendix 3 and OJP’s response is incorporated in 

Appendix 4 of this final report. In response to our draft audit report, OJP agreed

with our recommendations, and as a result, the status of the audit report is 

resolved. The following provide the OIG analysis of the response and summary of 

actions necessary to close the report.

Recommendation for OJP:

1. Coordinate with COVA to ensure that progress reports are accurate 

and fully supported. 

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

that it will coordinate with COVA to obtain a copy of its finalized and fully 

implemented Human Trafficking Program Policy and Protocol Handbook. 

COVA concurred with our recommendation. In its response, COVA included 

detailed actions that it will take to ensure that progress reports are accurate 

and fully supported. COVA also provided a copy of its draft Human 

Trafficking Program Policy and Protocol Handbook that includes its planned

procedures to ensure that progress reports are accurate and fully supported.

This recommendation can be closed when we receive documentation showing 

that COVA has finalized and fully implemented its Human Trafficking Program 

Policy and Protocol Handbook.

2. Coordinate with COVA to develop policies and procedures to ensure it 

adheres to all special conditions of the awards.

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

that it will obtain a copy of written policies and procedures, developed and 

implemented, to ensure COVA adheres to all special conditions.

COVA concurred that all special conditions were not submitted through the 

required GAN process and that four special conditions were met. However, 

COVA did not concur or only partially concurred with our findings for the 

remaining three special conditions because it had an explanation as to why it 

did not meet the special conditions. 

COVA partially agreed that special condition 43 for 2018-VT-BX-K036 was 

not met. COVA stated that it did not submit a revised time-task plan within 

30 days of the date of the award because there were no changes to the timetask plan submitted with the application and the Chief Deputy was not aware 
35

that the time-task plan was required to be resubmitted if there were no 

changes. However as stated in the report, a revised time-task plan was not 

submitted within 30 days of the date of the award, therefore the special 

condition was not met. 

COVA disagreed that special condition 50 for 2018-VT-BX-K036 was not met. 

COVA stated that it submitted a revised Privacy Certificate to the OVC 

Program Manager on January 9, 2019. However as stated in the report, the 

awardee is required to submit this information to OVC within 90 days of 

award. The date of award for 2018-VT-BX-K036 was September 27, 2018, 

which means COVA was required to submit a revised Privacy Certificate to 

the OVC Program Manager by December 26, 2018, to meet special condition 

50 for 2018-VT-BX-K036. 

COVA disagreed that special condition 57 for 2018-VT-BX-K036 was not met. 

COVA cited multiple reasons to justify spending funds prior to meeting this 

special condition. However, in addition to the specific incident COVA cites, as 

stated in the report COVA obligated payroll expenditures prior to the removal 

of special condition 57. 

This recommendation can be closed when we receive documentation showing 

that COVA has developed and implemented written policies and procedures 

to ensure it adheres to all special conditions of the awards. 

3. Coordinate with COVA to ensure it develops and implements new 

policies and procedures that include specific language regarding 

separation of duties, procurement, verifying that its vendors are not 

debarred or suspended from doing business with the federal 

government, approving and paying expenditures, matching costs, 

indirect costs, and performance measurement and outcome 

assessment.

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

that it will coordinate with COVA to obtain a copy of written policies and 

procedures, developed and implemented, to ensure compliance with grant 

administration requirements, including specific language regarding separation 

of duties; procurement; verifying that its vendors are not debarred or 

suspended from doing business with the federal government; approving and 

paying expenditures; matching costs; indirect costs; and performance 

measurement and outcome assessment.

COVA partially concurred with our recommendation. In its response, COVA 

stated that processes for separation of duties, approving and paying 

expenditures, and reporting are already outlined in the Board of Director’s 

Policy Manual. However, during our audit we reviewed the Board of 

Director’s Policy Manual and found that it did not include policies and 

procedures that clearly define separation of duties and it did not have specific 

language regarding approving and paying expenditures. COVA agreed that 

these processes should also be included in a separate Office Policies and
36

Procedures Manual that it anticipates will be completed by June 30, 2020. 

COVA also stated that the Office Policies and Procedures Manual will include 

specific language regarding policies and procedures for verifying that its 

vendors are not debarred or suspended from doing business with the federal 

government, matching costs, indirect costs, and performance measurement 

and outcome assessment. 

This recommendation can be closed when we receive documentation showing 

that COVA has developed and implemented new policies and procedures that 

include specific language regarding separation of duties, procurement, 

verifying that its vendors are not debarred or suspended from doing business 

with the federal government, approving and paying expenditures, matching 

costs, indirect costs, and performance measurement and outcome 

assessment.

4. Coordinate with COVA to ensure that all personnel costs charged to 

the awards are based on actual time and effort.

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

that it will coordinate with COVA to obtain a copy of written policies and 

procedures, developed and implemented, to ensure that all personnel costs 

charged to its federal awards are based on actual time and effort.

COVA concurred with our recommendation. In its response, COVA included 

detailed actions that it has or will take to ensure that personnel costs 

charged to the awards are based on actual time and effort. 

This recommendation can be closed when we receive documentation showing 

that COVA has developed and implemented written policies and procedures 

to ensure that all personnel costs charged to its Federal awards are based on 

actual time and effort.

5. Ensure that COVA include all award-related expenditures in its 

general ledgers for the awards.

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

that it will coordinate with COVA to obtain a copy of written policies and 

procedures, developed and implemented, for ensuring that all expenditures 

for each federal award are properly recorded in its general ledger.

COVA concurred with our recommendation. In its response, COVA stated 

that all expenditures are now entered into its accounting system by grant 

award.

This recommendation can be closed when we receive documentation showing 

that COVA has developed and implemented written policies and procedures

for ensuring that all expenditures for each federal award are properly 

recorded in its general ledger.
37

6. Remedy the $7,373 in unallowable questioned costs related to the 

$5,840 in unallowable personnel costs and $1,533 in unallowable 

other direct costs.

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

that it will review the $7,373 in unauthorized questioned costs related to 

$5,840 in personnel costs and $1,533 in other direct costs that were charged 

to Award Numbers 2015-VT-BX-K050 and 2018-VT-BX-K036; and work with 

COVA to remedy, as appropriate. 

COVA partially concurred with our recommendation. In its response, COVA 

stated that it feels the $5,840 for the unauthorized Spanish speaking intern 

was an allowable expense necessary to maintain services for Spanish 

speaking clients. However, COVA acknowledged that the personnel costs for 

the intern were not submitted to OJP for approval. COVA also stated that the 

$1,533 in unallowable other direct costs should not have been charged to the 

award. 

This recommendation can be closed when we receive documentation that OJP 

has remedied the $7,373 in unallowable questioned costs related to $5,840 

in unallowable personnel costs and $1,533 in unallowable other direct costs. 

7. Remedy the $207,953 in unsupported questioned costs related to the 

$12,418 in unsupported personnel costs and $195,535 in 

unsupported other direct costs.

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

that it will review the $207,953 in unsupported questioned costs related to 

$12,418 in unsupported personnel costs and $195,535 in unsupported other 

direct costs that were charged to Award Numbers 2015-VT-BX-K050 and 

2018-VT-BX-K036, and will work with COVA to remedy, as appropriate.

COVA partially concurred with our recommendation. In its response, COVA

stated that the $12,418 in personnel costs were unsupported. COVA also 

stated that moving forward fringe benefit costs will be calculated based on 

actual time and included in its accounting system. However, COVA partially 

agrees with our finding related to the $195,535 in unsupported other direct 

costs. In its response, COVA agreed that $195,535 related to gift cards was 

not totally supported with documented receipts. However, COVA stated that 

every gift card could be linked to a client’s case as indicated on an 

attachment provided along with its response. We disagree with this 

statement. The attached documentation provided was included in the 

documentation we reviewed as part of the audit. Based on our review, we 

found that the documentation did not provide any support that the gift cards 

were given to human trafficking clients or provide any information detailing

the purchases made using the gift cards.
38

This recommendation can be closed when we receive documentation that OJP 

has remedied the $207,953 in questioned costs related to $12,418 in 

unsupported personnel costs and $195,535 in unsupported other direct costs.

8. Remedy the $2,788 in unallowable matching funds.

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

that it will review the $2,788 in questioned costs related to unauthorized 

matching funds for Award Number 2018-VT-BX-K036, and will work with 

COVA to remedy, as appropriate.

COVA partially concurred with our recommendation. In its response, COVA 

stated that the Executive Director’s time was not submitted to OJP for 

approval through the GAN process; however, COVA felt that the cost of the 

executive Director’s time was allowable.

This recommendation can be closed when we receive documentation that OJP 

has remedied the $2,788 in questioned costs related to unallowable matching 

funds.

9. Remedy the $259,827 in unsupported matching costs.

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

that it will review the $259,827 in questioned costs, related to $250,000 in 

unsupported matching costs for Award Number 2015-VT-BX-K050 and 

$9,827 in unsupported matching costs for Award Number 2018-VT-BX-K036, 

and will work with COVA to remedy, as appropriate.

COVA did not concur with our recommendation. With its response, COVA 

provided additional information that it believed was sufficient to support its 

matching costs. As stated in the report, we found that for matching costs 

related to trainings, the only supporting documentation was a list of trainings 

that COVA either attended or provided, the number of attendees, and the 

number of training hours. However, COVA did not maintain training 

agendas, sign in sheets, or any other documentation to support the 

information listed. We reviewed the documentation COVA provided along 

with its response to the draft report to identify any new documentation. 

COVA’s additional documentation included a list of trainings that COVA 

previously provided and was reviewed as part of the audit, and an additional 

four sign-in sheets, three meeting agendas, and email correspondence 

between its employees and individuals representing other organizations. 

Based on our review, we found that the additional documentation did not 

fully support any of the questioned matching costs identified in the report. 

In its response, COVA also stated it has a new policy in place for tracking

matching costs in spreadsheet tied to its accounting system. However, 

COVA’s new policy does not address the required documentation necessary 

to fully support its matching costs. 
39

This recommendation can be closed when we receive documentation that OJP 

has remedied the $259,827 in unsupported matching costs. 

10. Coordinate with COVA to ensure it meets its matching requirements, 

tracks all matching transactions on its general ledgers, and 

implements new policies and procedures to ensure matching costs 

are properly supported.

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

that it will coordinate with COVA to ensure that it meets matching 

requirements for Award Number 2018-VT-BX-K036. OJP also stated that it 

will coordinate with COVA to obtain a copy of written policies and procedures, 

developed and implemented, to ensure that all matching transactions are 

recorded in its general ledger and are properly supported.

COVA concurred with our recommendation. In its response, COVA stated 

that its Executive Director and Chief Deputy Director will work with the OVC 

Program Manager to establish how the matching will be met for the current 

award. 

This recommendation can be closed when we receive documentation showing 

that OJP has coordinated with COVA to ensure that it meets matching 

requirements for Award Number 2018-VT-BX-K036 and COVA has written 

policies and procedures, developed and implemented, to ensure that all 

matching transactions are recorded in its general ledger and are properly 

supported.

11. Coordinate with COVA to ensure it submits accurate FFRs. 

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

that it will coordinate with COVA to obtain a copy of written policies and 

procedures, developed and implemented, to ensure that future FFRs are 

accurately prepared, and reviewed and approved by management prior to 

submission; and the supporting documentation is maintained for future 

auditing purposes.

COVA concurred with our recommendation. In its response, COVA stated

that the Executive Director and the bookkeeper will review all financial 

expenditures for accuracy on a quarterly basis prior to submitting the FFR. 

COVA also stated that this process will be added to the Office Policies and

Procedures Manual.

This recommendation can be closed when we receive documentation that 

COVA has developed and implemented written policies and procedures to 

ensure that future FFRs are accurately prepared and reviewed and approved 

by management prior to submission; and the supporting documentation is 

maintained for future auditing purposes.
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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