REDACTED FOR PUBLIC RELEASE

Office of the Inspector General

U.S. Department of Justice

OVERSIGHT ★ INTEGRITY ★ GUIDANCE

Audit of the Office on Violence Against 

Women Grant Awarded to

Life Span, Chicago, Illinois 

REDACTED FOR PUBLIC RELEASE

Redactions were made to the full version of this report for privacy reasons. The redactions are contained only in Appendix 3, Life Span’s response, and are of individuals’ names and identifying pronouns.

Audit Division 20-022 January 2020

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Executive Summary 

Audit of the Office on Violence Against Women Grant Awarded to 

Life Span, Chicago, Illinois 

Objectives 

The Department of Justice (DOJ) Office on Violence 

Against Women (OVW) awarded Life Span a grant 

totaling $600,000 for the Legal Assistance to Victims 

(LAV) program. The objectives of this audit were to 

determine whether costs claimed under the grant were 

allowable, supported, and in accordance with applicable 

laws, regulations, guidelines, and terms and conditions 

of the award; and to determine whether the grantee 

demonstrated adequate progress towards achieving 

program goals and objectives. 

Results in Brief 

As a result of our audit, we concluded that Life Span is 

working to achieve the goals and objectives of the OVW 

award, but must enhance its process to adequately track 

and report its performance. We also identified areas of 

improvement in Life Span’s financial management 

structure and compliance with grant requirements. For 

instance, Life Span’s policies did not incorporate details 

for certain grant-related procedures, such as completing 

the Federal Financial Reports (FFRs), and did not 

designate back-up personnel to perform essential tasks. 

In addition, we determined that Life Span’s drawdown 

procedures resulted in advancing $5,150 in grant funds 

that were not expended within the required timeframe. 

We also identified that Life Span charged the grant for 

$4,221 in unallowable costs associated with expenses 

related to personnel and fringe benefits. 

Recommendations 

Our report contains seven recommendations to the 

OVW. We requested a response to our draft audit report 

from the OVW and Life Span, and their responses are 

appended to this final report in Appendices 3 and 4, 

respectively. Our analysis of those responses is included 

in Appendix 5. 

Audit Results 

The purpose of the OVW grant we reviewed was to 

provide legal services to victims of domestic and sexual 

violence in Cook County, Illinois. The project period for 

the grant was from October 2017 through 

September 2020. As of March 31, 2019, Life Span drew 

down a cumulative amount of $254,209 for the grant. 

Program Goals and Accomplishments – Life Span 

demonstrated progress toward completing award goals 

and objectives. However, we identified concerns with 

the process Life Span used to track performance 

metrics. Specifically, the support used for Life Span’s 

July 1, 2018, through December 31, 2018, progress 

report did not account for staffing changes and their 

associated effect on tracking performance metrics, which 

impacted our ability to reconcile and verify the 

information. 

Grant Financial Management - We found that 

although the Deputy Executive Director performed many 

grant-related tasks, Life Span’s policies and procedures 

did not provide adequate details or designate back-up 

personnel for completing these requirements. 

Grant Expenditures - We found that Life Span charged 

$3,446 in unallowable costs associated with changes in 

personnel expenses that were not approved by the 

OVW, as well as $775 in fringe benefits that were not 

included in the OVW-approved budget. 

Drawdowns - As of January 9, 2019, Life Span had 

drawn down a total of $254,209 in award funds. Life 

Span’s total expenses at that time totaled $249,059, 

which resulted in Life Span receiving $5,150 in advanced 

grant funds. Life Span officials attributed this advance 

to the misallocation of an expense, which was not 

identified until after the drawdown occurred. 

Federal Financial Reports - Life Span submitted six 

FFRs during our review period, but did not accurately 

report its grant expenses for any given reporting period. 

In addition, three of six FFRs erroneously duplicated 

expenses, which resulted in Life Span submitting 

inaccurate information to the OVW. 

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AUDIT OF THE 

OFFICE ON VIOLENCE AGAINST WOMEN GRANT 

AWARDED TO LIFE SPAN, 

CHICAGO, ILLINOIS 

TABLE OF CONTENTS 

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

The Grantee .........................................................................................1 

OIG Audit Approach ..............................................................................1 

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

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

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

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

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

Grant Financial Management ..................................................................5 

Budget Management and Control ............................................................6 

Grant Expenditures ...............................................................................6 

Salary Costs................................................................................7 

Other Personnel Costs ..................................................................8 

Rent ........................................................................................8 

Drawdowns ..........................................................................................8 

Federal Financial Reports .......................................................................9 

CONCLUSION AND RECOMMENDATIONS......................................................... 11 

APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY ................................. 12 

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS................................ 13 

APPENDIX 3: LIFE SPAN’S RESPONSE TO THE DRAFT AUDIT REPORT................ 14 

APPENDIX 4: OFFICE ON VIOLENCE AGAINST WOMEN’S RESPONSE TO THE 

DRAFT AUDIT REPORT......................................................................... 18 

APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE AUDIT REPORT ......................... 21 
 

 

 

 

 

 

 

 

 

AUDIT OF THE 

OFFICE ON VIOLENCE AGAINST WOMEN GRANT 

AWARDED TO LIFE SPAN, 

CHICAGO, ILLINOIS 

INTRODUCTION 

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

completed an audit of a grant awarded by the Office on Violence Against Women 

(OVW), Legal Assistance for Victims (LAV) Program, to Life Span in Chicago, Illinois. 

Life Span was awarded one grant totaling $600,000, as shown in Table 1. 

Table 1 

Grant Awarded to Life Span 

Award Number Program 

Office Award Date 

Project 

Period Start 

Date 

Project 

Period End 

Date 

Award 

Amount 

2017-WL-AX-0035 OVW 9/22/2017 10/1/2017 9/30/2020 $600,000 

Total: $600,000 

Source: OJP’s Grants Management System 

According to the OVW, funding through the LAV Program is intended to 

increase the availability of civil and criminal legal assistance programs for adult and 

youth victims of domestic violence, dating violence, sexual assault, and stalking 

who are seeking relief in legal matters relating to or arising out of that abuse or 

violence. 

The Grantee 

Founded in 1978, Life Span provides services for women and children who 

are victims of domestic and sexual violence, including legal services, advocacy, and 

counseling. Life Span’s mission is to empower survivors of domestic and sexual 

violence to demand safety as a human right through client-centered services and 

lead social change through accountability, community engagement, and systemic 

advocacy. 

OIG Audit Approach 

The objectives of this audit were to determine whether the grantee 

demonstrated adequate progress towards achieving the program goals and 

objectives; and to determine whether costs claimed under the grant were 

allowable, supported, and in accordance with applicable laws, regulations, 

guidelines, and terms and conditions of the grant. To accomplish these objectives, 

we assessed performance in the following areas of grant management: program 

performance, financial management, expenditures, budget management and 

control, drawdowns, and Federal Financial Reports (FFRs). 

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

conditions of the grant. The DOJ Grants Financial Guide 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. 

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AUDIT RESULTS 

Program Performance and Accomplishments 

We reviewed required performance reports, grant documentation, and 

interviewed grantee officials to determine whether Life Span 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 Life Span’s compliance with the special conditions identified in 

the award documentation. 

Program Goals and Objectives 

The OVW awarded the LAV Grant Number 2017-WL-AX-0035 to Life Span to 

provide legal services to victims of domestic and sexual violence in Cook County, 

Illinois. Through this grant, Life Span set out to achieve the following goals: 

(1) provide victims of domestic and sexual violence a permanent civil legal 

resolution to critical issues and strengthen Life Span’s ability to provide these 

services; 

(2) increase the safety and crisis planning of victims of domestic and sexual 

violence seeking civil legal assistance at Life Span, including respondents; 

(3) provide a response for victims of domestic violence who are wrongly sued 

as respondents in order of protection cases; 

(4) ensure that the proposed project is fully integrated into Life Span, and 

that services remain victim-oriented, sensitive, safe, and complementary to 

other services offered by Life Span and other domestic violence and sexual 

assault agencies; and 

(5) increase knowledge and understanding of domestic violence services 

through the sharing of expertise gained from project implementation. 

These goals are ongoing and require Life Span staff to provide a multitude of 

services and assistance to victims. We found that Life Span was making progress 

in achieving these goals as reflected by key activities that include, but are not 

limited to, screening applicants to provide appropriate services, informing clients of 

their rights, assisting clients in developing safety and crisis readiness plans, and 

handling all legal matters for clients until litigation is complete. 

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 

10 performance measures from the 2 most recent progress reports submitted to 

the OVW and attempted to trace the information reported for these measures to 

supporting documentation maintained by Life Span. We found that Life Span’s 

January 1, 2018, through June 30, 2018, progress report was supported. However, 

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the support used for Life Span’s subsequent progress report for the period 

July 1, 2018, through December 31, 2018, did not account for changes in tracking 

performance metrics resulting from staffing changes, which impacted our ability to 

reconcile and verify the information. 

For this grant, Life Span tracked its activity related to the established 

performance metrics using data related to work performed by its grant-funded staff 

members. On September 1, 2018, Life Span replaced a staff attorney who worked 

solely on the grant with a supervisory attorney who worked part-time on the grant. 

However, when Life Span compiled its performance metrics for the progress report 

for this time period, it did not adjust its tracking methodology to properly account 

for the staffing changes associated with the grant. In reporting its performance for 

the second half of the 2018 calendar year, Life Span excluded the original staff 

attorney’s statistics in total, even though that individual was funded by the grant 

and contributing to grant-funded accomplishments for the period between 

July 1, 2018, and August 31, 2018. In turn, Life Span included the replacement 

supervisory attorney’s statistics for the entire reporting period rather than 

excluding services provided prior to September 1, 2018. In addition, Life Span’s 

documentation did not specifically identify or isolate the grant-funded work of this 

attorney because it did not delineate the work that this attorney did for the OVW 

grant separate from other Life Span programs. As a result, we could not verify with 

certainty that the metrics reported during this reporting period accurately reflected 

the OVW grant performance. We discussed these concerns with Life Span officials 

and they agreed that the methodology used to compile the statistics associated 

with the progress report could have resulted in reporting imprecise results. 

In addition, we found that Life Span does not have formalized policies and 

procedures for tracking performance measures and submitting progress reports to 

the OVW. Life Span officials explained that the process for compiling data and 

submitting the progress reports to the OVW is informal, includes multiple staff 

members, and requires approval from the Executive Director. Historically, 

Life Span relied on a web-based system to standardize its data collection and fulfill 

its reporting requirements. In August 2018, Life Span acquired a new internal case 

management system, which allowed Life Span to streamline its data management 

and reporting practices for the OVW’s progress reports. A Life Span official stated 

that Life Span currently utilizes a hybrid approach to answering progress report 

questions, using information from both the web-based system and its new internal 

system, as well as case information from the three funded staff members. 

However, as reflected in our review, Life Span did not adjust this methodology 

when staffing changes occurred, which ultimately affected the accuracy of its 

progress report to the OVW for the LAV grant. In addition, because Life Span uses 

a multi-pronged approach, we believe that lack of formalized procedures increases 

the risk that Life Span is not adequately tracking its grant activities against stated 

goals and objectives. As a result, we recommend that the OVW ensure that 

Life Span formalizes and enhances its performance data collection and reporting 

methodology to ensure that progress reports are accurate and supported and that it 

is adequately tracking data related to the intended goals and objectives of the 

grant. 

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Compliance with Special Conditions 

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

award. We evaluated the special conditions for the grant and selected a 

judgmental sample of the requirements that are significant to performance under 

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

three special conditions: (1) registration with the federal System for Award 

Management (SAM), (2) participation in OVW technical assistance training, and 

(3) submission of case selection criteria for grant-funded services to the OVW 

within 90 days of award acceptance. We found that Life Span generally fulfilled 

these special conditions. However, Life Span missed its case selection criteria 

submission deadline by 19 days. Life Span ultimately complied with this special 

condition and its case selection criteria was approved by the OVW; therefore the 

OVW did not initiate a hold on the availability of funds. Because Life Span rectified 

the problem and the OVW approved it, we do not make a recommendation. 

Grant Financial Management 

According to the DOJ Grants Financial Guide, all grant recipients and 

subrecipients are required to establish and maintain adequate accounting systems 

and financial records and to accurately account for funds awarded to them. To 

assess Life Span’s financial management of the grant covered by this audit, we 

interviewed financial staff, examined policies and procedures, and inspected grant 

documents to determine whether Life Span adequately safeguards the grant funds 

we audited. We also reviewed Life Span’s Single Audit Reports for fiscal years (FY) 

2016 through 2018 to determine if there were any internal control weaknesses or 

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

testing in the areas that were relevant for the management of this grant, as 

discussed throughout this report. 

Our review of the Single Audit Reports did not reveal significant deficiencies 

or material weaknesses related to grant administration, and we found that Life 

Span implemented formalized financial management procedures that accounted for 

grant funds. However, we identified certain weaknesses in Life Span’s financial 

management. During the audit, we learned that Life Span’s Deputy Executive 

Director completed many of the grant’s approval and reporting activities. While it 

was acceptable that this individual performed these tasks, there were no 

documented procedures detailing certain tasks, to include grant reporting, budget 

development, and financial allocation planning. There was also not a formally 

designated back-up individual to perform these tasks in the Deputy Executive 

Director’s absence. If this individual were to leave the organization, this grant 

management knowledge would be lost and Life Span could experience difficulty in 

accurately completing grant-related activities. Therefore, we recommend that the 

OVW work with Life Span to ensure Life Span has implemented and disseminated 

new policies and procedures documenting all grant-related responsibilities, 

including those performed by the Deputy Executive Director, and designated a 

back-up individual for this individual’s tasks. 

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-

Additionally, our review of grant expenditures identified unallowable costs 

charged to the grant, and we found deficiencies in Life Span’s processes for drawing 

down grant funds and completing FFRs. These issues are discussed in further detail 

in the following sections of this report. 

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 grant recipient must initiate a Grant Adjustment Notice 

(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 found that Life Span’s policies and procedures include a process to 

compare expenditures to budget amounts. In addition, when we compared grant 

expenditures to the approved budgeted amounts, we determined that the 

cumulative difference between category expenditures and approved budget 

category totals was not greater than 10 percent. 

Grant Expenditures 

For Life Span’s LAV grant, the approved budget included salaries, fringe 

benefits, travel, contractual (translation services), and other (rent). The following 

table provides an overview of Life Span’s budgeted and actual expenditures by 

category. 

Table 2 

OVW-Approved Budget and Life Span Expenses 

as of March 2019 

Budget Category OVW Approved 

Budget 

Life Span 

Expenses 

Salaries $445,850 $232,593 

Fringe $98,684 $46,661 

Travel $6,300 $2,845 

Contractual $750 $0 

Other $48,416 $14,897 

Total $600,000 $296,996 

Source: OJP’s Grants Management System and Life Span’s 

Accounting Records 

To determine whether costs charged to the award were allowable, supported, 

and properly allocated in compliance with award requirements, we tested a 

judgmental sample of transactions. This sample included 27 transactions totaling 

$67,362 and covered all budget categories associated with Life Span’s expenses at 

the time of our fieldwork. We reviewed documentation and accounting records, and 

we performed verification testing related to these grant expenditures. Based on 

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this testing, we recommend that the OVW remedy $4,221 in questioned costs, as 

described in the following sections. 

Salary Costs 

Life Span stated in its budget narrative that the project would cover the 

salaries and fringe benefits for three full-time (40 hours per week) staff members. 

During our review of Life Span’s payroll documentation, we found that in May 2018, 

Life Span management allowed a staff attorney to reduce their schedule to 

32 hours per week, but did not change this attorney’s salary amount. Because this 

attorney was no longer working the full-time schedule that the OVW approved, we 

believe that Life Span should have submitted a GAN and received approval from the 

OVW for this change. We reviewed the payroll expenses for this attorney and 

determined that Life Span charged the grant $17,232 for the attorney’s salary 

between May 1, 2018, and August 31, 2018. Because this attorney worked 

20 percent less time on the grant, we found that $3,446 of these costs were 

unallowable. We recommend that the OVW work with Life Span to remedy $3,446 

in unallowable salary expenses. 

In addition, this attorney who was working 32 hours per week was the 

individual who was replaced with another attorney in September 2018.1 Life Span 

notified the OVW of this change through a GAN, and stated that the new attorney's 

salary would remain the same as the previous attorney’s salary. However, 

Life Span did not inform the OVW that the new attorney would also not work 

full-time on the grant. Specifically, we found that the new attorney was a 

supervisor for Life Span and had a higher salary than the previous attorney, so Life 

Span used the OVW grant, as well as funding from other sources to pay for this 

supervisory attorney’s salary. Consequently, this attorney was not devoting 

40 hours per week to the OVW grant. According to Life Span documentation, it was 

determined that the OVW grant would cover 55 percent of this attorney’s salary, 

because this amount equated to salary costs that the OVW approved in the budget. 

We reviewed a sample of the attorney’s timesheets and found that although the 

time spent on OVW grant activities fluctuated, this attorney generally met or 

exceeded the 55 percent of time allocated to the grant. However, we believe that 

when Life Span submitted the GAN for the change in personnel, it should have 

incorporated information about the change in time and effort, so that the OVW 

could review and, if appropriate, approve the arrangement. We do not question 

any costs associated with the personnel expenses for this attorney because the 

attorney’s work was supported by adequate documentation and Life Span had 

notified the OVW of the personnel change, but recommend that the OVW work with 

Life Span to ensure that the change in time and effort and cost allocation 

methodology associated with the senior attorney assigned to the LAV grant is 

appropriate and acceptable. 

1 This staff change was first discussed in the Required Performance Reports section of this 

report. 

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Other Personnel Costs 

During our review of Life Span’s general ledger, we identified $775 in an 

expense related to an attorney’s pension. However, Life Span’s OVW-approved 

budget did not include pension costs. Therefore, we recommend that the OVW 

work with Life Span to remedy $775 in unapproved fringe benefits. We spoke with 

a senior Life Span official about these questioned costs and this individual 

acknowledged the need to coordinate with the OVW on these issues. 

Rent 

Life Span’s original budget estimated a total of $48,416 in rent expenses for 

office space for the 3-year period of the grant. At the time of the application in 

February 2017, this estimate was calculated based on the total rent cost of $94,935 

annually, with 3 funded staff members accounting for 17 percent of Life Span’s total 

18 staff members. This methodology was approved by the OVW. In January 2018, 

Life Span moved offices to account for an increase in staff members and a need for 

larger space. Life Span submitted a GAN to notify the OVW of a change in mailing 

address but did not explain that Life Span’s new office location was larger and 

required a new rent allocation estimate for the grant to account for the increased 

rent cost. Specifically, when Life Span moved its office space, its rent almost 

doubled to $172,250 annually, and its staff increased from 18 to 23 individuals. 

When we reviewed Life Span’s grant expenditures, we found that Life Span 

had expended $14,897 in grant funds on rent as of March 2019. This amount is 

within the budgeted amount, but we believe that Life Span should submit a GAN to 

the OVW that accounts for the new rental allocation methodology to ensure that the 

grant is not overcharged for these expenses. Consequently, we recommend that 

the OVW work with Life Span to ensure that its rent allocation costs are 

appropriate, allowable, and supported. 

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 grant award, recipients have drawn down funds in 

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

agency. 

According to Life Span’s financial procedures, funding reimbursement 

requests shall only be made after Life Span has incurred an expenditure that 

represents allowable costs. These procedures also specify that drawdowns are 

based on immediate reimbursement requirements to ensure that federal cash on 

hand is the minimum needed, either immediately or within 10 days. Drawdown 

requests are developed by accounting staff who prepare a voucher containing only 

eligible expenditures that are reconciled with the general ledger. The Executive 

Director reviews the voucher and indicates approval by signing and dating the 

voucher, which is then used to seek reimbursement from the OVW. 

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To assess whether Life Span managed grant receipts in accordance with 

federal requirements, we compared the total amount reimbursed by the OVW to the 

total expenditures in Life Span’s accounting records. As of March 31, 2019, 

Life Span had drawn down a total of $254,209 in award funds. Life Span’s last 

drawdown during this time period occurred on January 9, 2019, and Life Span’s 

total recorded expenses at that time were $249,059, which resulted in Life Span 

receiving $5,150 in advanced grant funds. Life Span did not expend this amount 

within 10 days of the drawdown, as required. As a result, we are questioning the 

$5,150 in advanced drawdowns as unallowable, and are recommending that the 

OVW work with Life Span to resolve these questioned costs. We discussed this 

drawdown advance with a senior Life Span official who stated this occurred because 

of a misallocation of expenses in Life Span’s accounting system. Life Span 

identified this misallocation during its monthly expense reconciliation process, which 

occurred after Life Span drew down the funds from the OVW. This official stated 

that Life Span will work to ensure future drawdowns are accurate. However, we 

recommend that Life Span enhance its process to verify that all expenses identified 

in the accounting system are allocated correctly to the grant prior to drawing down 

funds. 

Federal Financial Reports 

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

expenditures and unliquidated obligations incurred for the reporting period on each 

financial report as well as cumulative expenditures. To determine whether 

Life Span submitted accurate FFRs, we compared the six most recent reports to 

Life Span’s accounting records. 

We found that as of March 2019, the aggregate amount identified on the 

FFRs matched Life Span’s accounting records. However, Life Span never accurately 

reported its grant expenses for any given reporting period, as shown in the 

following table. 

Table 3 

Federal Financial Reports 

Reporting Period Expenditures 

Reported on FFR 

Expenditures 

Recorded in 

Accounting 

Records 

Difference 

10/01/2017 – 12/31/2017 $47,499 $48,696 $1,197 

01/01/2018 – 03/31/2018 $45,366 $46,465 $1,099 

04/01/2018 – 06/30/2018 $50,166 $49,904 ($262) 

07/01/2018 – 09/30/2018 $52,026 $51,537 ($489) 

10/01/2018 – 12/31/2018 $51,292 $50,503 ($789) 

01/01/2019 – 03/31/2019 $50,647 $49,891 ($756) 

Total: $296,996 $296,996 $0 

Source: OJP’s Grants Management System 

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We also found that the three most recent FFRs submitted by Life Span 

erroneously included duplicate expenses in two different categories, which resulted 

in Life Span submitting inaccurate figures for its unobligated balance. 

When we spoke with the Life Span official who submitted the FFRs, this 

official stated that there was confusion about the categories required on the FFRs, 

but that Life Span would update its process and ensure that the information 

submitted was correct. We believe that this discrepancy was also the result of Life 

Span not having written policies and procedures for preparing and submitting FFRs. 

Therefore, we recommend that the OVW work with Life Span to enhance its policies 

and procedures for preparing and submitting FFRs. 

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CONCLUSION AND RECOMMENDATIONS 

As a result of our audit, we conclude that Life Span did not adhere to all of 

the grant requirements we tested, but demonstrated that it was making progress 

towards achieving the grant’s stated goals and objectives. We also did not identify 

significant issues regarding Life Span’s adherence to grant special conditions. 

However, we found that Life Span did not consistently support or accurately report 

performance measurements, which could have resulted from an imprecise data 

management and reporting methodology. We also found that Life Span charged 

the grant for unallowable costs associated with salaries and fringe benefits, and 

that Life Span did not ensure that the OVW was aware of all personnel and rent 

allocation changes that have occurred. In addition, we found that Life Span could 

improve its processes for conducting drawdowns and reporting its information 

through FFRs. We provide seven recommendations to the OVW to address these 

deficiencies. 

We recommend that the OVW: 

1. Verify that Life Span enhances its performance data collection and reporting 

methodology for progress reports and adequately tracks data related to the 

intended goals and objectives of the grant. 

2. Ensure Life Span has implemented and disseminated new policies and 

procedures documenting the Deputy Executive Director’s grant-related 

responsibilities, which includes the designation of back-up personnel. 

3. Ensure that Life Span’s changes in time and effort and cost allocation 

methodology associated with the senior attorney assigned to the grant is 

appropriate and acceptable. 

4. Remedy $9,371 in unallowable costs, specifically: 

a. $3,446 in unapproved costs associated with salary expenses; 

b. $775 in pension-related fringe benefits not approved by the OVW; and 

c. $5,150 in unallowable advanced drawdowns. 

5. Coordinate with Life Span to ensure that its rent allocation costs are 

appropriate, allowable, and supported. 

6. Ensure that Life Span enhances its process to verify that all expenses 

identified in the accounting system are allocated correctly to the grant prior 

to drawing down funds. 

7. Ensure that Life Span enhances its policies and procedures for preparing and 

submitting FFRs. 

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APPENDIX 1 

OBJECTIVES, SCOPE, AND METHODOLOGY 

Objectives 

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

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

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

whether the grantee demonstrated adequate progress towards achieving the 

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

performance in the following areas of grant 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 an Office on Violence Against Women (OVW) grant 

awarded to Life Span under the Legal Assistance for Victims (LAV) Program. The 

OVW awarded $600,000 through Grant Number 2017-WL-AX-0035 to Life Span. 

Our audit concentrated on, but was not limited to October 1, 2017, the award start 

date, through March 31, 2019. As of March 31, 2019, Life Span had drawn down 

$254,209 of the total grant funds awarded. 

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

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

grant. We performed sample-based audit testing for grant expenditures including 

payroll and fringe benefit charges, financial reports, and progress reports. In this 

effort, we employed a judgmental sampling design to obtain broad exposure to 

numerous facets of the grant reviewed. This non-statistical sample design did not 

allow projection of the test results to the universe from which the samples were 

selected. The DOJ Grants Financial Guide and the award documents contain the 

primary criteria we applied during the audit. 

During our audit, we obtained information from OJP’s Grants Management 

System, as well as Life Span’s 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 were verified with documentation from other sources. 

12 
 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

Description Amount Page 

Questioned Costs: 

Unapproved Personnel Expenses $3,446 7 

Unapproved Pension Costs 775 8 

Advanced Grant Funds 5,150 9 

Unallowable Costs $9,371 

 

Total Questioned Costs $9,371 

13 
 

APPENDIX 3 

LIFE SPAN’S RESPONSE TO THE DRAFT AUDIT REPORT 

14 

70 E. Lake Street, Suite 600 

Chicago, IL 60601 

Tel: (312) 408-1210 

Fax: (312) 408-1223 

www.life-span.org 

18, 2019 

Carol S. Taraszka 

Regional Audit Manager 

U.S. Department of Justice 

Office of the Inspector General 

500 West Madison Street, Suite 1121 

Chicago, Illinois 60661-2590 

Dear Ms. Taraszka: 

Life Span is in receipt of the draft audit report issued by the U.S . Department of Justice, 

Office of the Inspector General (DOJ OIG) Audit Division on November 20, 20 19. This audit 

relates to Life Span's Violence Against Women, Legal Assistance for Victims Program Grant 

Award, 2017 WL AX 0035. 

The DOJ OIG recommendations made within the report and Life Span's responses to the 

recommendations are as follows: 

I. Verify that Life Span enhances its performance data collection and reporting 

methodology for progress repo1is and adequately tracks data related to the intended 

goals and objectives of the grant. 

Response: Life Span concurs with this recommendation and affirmatively states that 

prior to the audit, Life Span had purchased a new data management system, 

LegalServer, to enhance our data collection and repo1iing abilities. 

2. Ensure Life Span has implemented and disseminated new policies and procedures 

documenting the Deputy Executive Director's grant-related responsibilities, which 

includes the designation of back-up personnel. 

Response: Life Span concurs with this recommendation. 

3. Ensure that Life Span's changes in time and effort and cost allocation methodology 

associated with the senior attorney assigned to the grant is appropriate and acceptable. 
Response: Life Span concurs with this recommendation and affirmatively states that 

prior to the issuance of the draft audit report, on October 28, 2019, Life Span 

submitted a GAN addressing the time and effort and cost allocation methodology 

associated with the staff changes. The GAN states in relevant part as follows, Life 

Span names redacted and replaced with job title: 

December 5, 2018 GAN Clar(fication: On November 9, 2018, we notified our grant 

specialist, ■■■■■■ofa staffchange on the funded project and inquired ifa 

GAN was necessary. On November 23, 2018, ■■■■ i11structed Life Span to 

submit a GAN "with the changes in staff" along with the new staffperson's resume. 

On December 5, 2018, L(fe Span submitted a GAN to advise O VW that one ofthe 

funded staffatlorneys, ■■■■■■ was no longer assigned to the funded project 

as ofSeptember 1, 2018. We request~ fund s the 

replacement attorney. We submilled --·eswne. 

Since that time, we have been instructed by Program Analyst, 

Office ofthe Inspector General, U.S. Depart men/ ofJuslice, that our GANshould 

have included additional in.formation. With this knowledge we are providing the 

following clar!fication: 

• --is not.fully.funded by our OVWgrant. - snow Life Span's Legal 

Director and earns, $84,240 per year. The original budge/ for that position was 

$53,309 per year. OVW.f1mds support 65% o.f- a/a,y andjimds llllll'1rovision o.f 

direcl services consistent with those described in our program narrative. 

Given ■■■■■■evel ofexperience, . service levels are consistent with 

!hose originally projected for the staffattorney in our program narrative. 

4. Remedy $9,371 in unallowable costs, specifically: 

a. $3,446 in unapproved costs associated with salary expenses; 

Response: Life Span concurs with this recommendation and affirmatively 

states that on October 28, 2019, Life Span submitted a GAN to address the 

costs associated with this salary expenses and request that they be allowed. 

The GAN states in relevant part as fo llows: 

Retroactive GAN requests as a result ofour OIG a11di1: Starting May 18, 

2018, one ofthe funded staffattorneys, reducedho11rsfrom 40 !tours per week to 32 hours per week. While this is still 

consideredfi,ll-time employment at Life Span, it was not consistent with our 

budget narrative in which we stated the staffattorney would work ".full-time 

(minimum of40 hours/week). " At this time, was promoted to 

a Senior Allorney position. As Senior Attorney, upervised the 

funded project staff Given . added responsibilities, - ala,y did not 

15 
change. - eve/ ofservice provision remained consistent with that 

projected in our program narrative. 

b. $775 in pension-related fringe benefits not approved by the OVW; and 

Response: Life Span concurs with this recommendation and affirmatively 

states that on October 28, 2019, Life Span submitted a GAN to address the 

pension costs. The GAN states in relevant part: 

Life Span's budget narrative did not include pension costs in the fringe 

benefits description. Life Span has a 403b pension plan whereby 

participating staffare eligible/or an annual contribution of1.5% oftheir 

sala,y on a discretiona,y basis at the end ofeachfisca/ year. In June 2018, 

funded staffreceived $775.44 and in June 2019,fimded sta_ffreceived $738. 

We request that OVW.funds pay this fringe benefit cost. Given a reduction in 

health insurance costs. we project our overall fringe expenses to come in 

under budget by about $2,500. 

c. $5,150 in unallowable advanced drawdowns. 

Response: Life Span concurs with this recommendation. 

5. Coordinate with Life Span to ensure that its rent allocation costs are appropriate, 

allowable, and supported. 

Response: Life Span concurs with this recommendation and affirmatively states that 

on October 28, 2019, Life Span submitted a GAN to address the rent costs. The GAN 

states in relevant part as follows: 

In Life Span's Budget Narrative, we requested $48,416 tojimd rental costs/or 

project SU!/J At that time. the project operated.from a leased suite in the 

downtown Chicago o_flice building that houses our Center/or Legal Services and 

Advocacy. The suite was 4,552 square feet and cost on average a $94,935 per 

year to rent. Project staffcomprised 3 out ofI 8 Life-Span staffmembers housed 

at that location, or 17% o_fthe staffwho work from our Center.for Legal Services 

and Advocacy. 

From the beginning ofthe grant period, October I, 2017 through June 30, 2018, 

L{fe Span did not require OVW fimds to support the rental costs ofthe funded 

project. We reserved the use ofthese fimds because soon after the grant period 

began, our existing lease ended and we negotiated an expansion ofour o_ffice 

space. 

16 
On January 5, 2018, we moved into a new office suite with 6,625 square.feet at an 

annual cost of$172,250. Project sta_ffcomprised 3 out of21 FTE sta_ffhoused in 

that suite, or 15%. Starting July 1, 2018, we allocated O VW jimdsfor the 

payment ofrent in that location at a cost of$1,862.17/month. This amount is less 

than the 15% expense allributable to the funded staff($2, 153/mo.) but was 

consistent with our overall budgeted rent allocation/or the remaining duration of 

the grant period. 

in September 2018, - ·ep/aced 

attorney on the project. OVWjimds support 65% of salm:v. At 

this time, the amount ofrental space attributed to the grant. decreased from 15% 

(3 FTE/21 FTE) to 13% (2.65 FTE/2/FTE). While the FTE changed, we 

continued to allocate $1,862.17/month in OVWfunds for the payment ofrent. 

This remains less than the amount we could attribwe to the grant ($1,866.05/mo). 

6. Ensure that Life Span enhances its process to verify that all expenses identified in the 

accounting system are allocated correctly to the grant prior to drawing down funds. 

Response: Life Span concurs with this recommendation. 

7. Ensure that Life Span enhances its policies and procedures for preparing and 

submitting FFRs. 

Response: Life Span concurs with this recommendation. 

We look forward to OVW's responses to our outstanding GANs. Further, we appreciate 

the opportunity to work with OVW to ensure that we administer grants funds in compliance with 

fiscal and administrative requirements. 

l..c/lllA--7~ IA L4/II!~IJv--

enice Wolf ~ {' 

Executive Director 

17 
APPENDIX 4 

OFFICE ON VIOLENCE AGAINST WOMEN’S 

RESPONSE TO THE DRAFT AUDIT REPORT 

18 

U.S. Department of Justice 

Office on Violence Against Women 

Washington, DC 20530 

January 8, 2020 

TO: Carol Taraszka 

Regional Audit Manager 

FROM: Nadine M. Neufville -41\-VV'-(\ 

Deputy Director, Grants Development and Management 

Donna Simmonsk19 

Associate Director, Grants Financial Management Unit 

Rodney Samuels --fil 

Audit Liaison/Staff Accountant 

SUBJECT: Draft Audit Report - Audit of the Office on Violence Against 

Women (OVW) Grant Awarded to Life Span, Chicago, Illinois 

This memorandum is in response to your correspondence dated November 20, 2019 transmitting 

the above draft audit repo1t for Life Span. We consider the subject report resolved and request 

written acceptance of this action from your office. 

The report contains seven recommendations with $9,371 of Questioned Costs. OVW is 

committed to addressing and bringing the open recommendations identified by your office to a 

close as quickly as possible. The following is our analysis of each recommendation. 

I. Verify that Life Span enhances its performance data collection and reporting 

methodology for progress reports and adequately tracks data related to the intended goals 

and objectives of the grant. 

Concur: OVW will coordinate with Life Span to verify that they enhance its performance data 

collection and repo11ing methodology for progress reports and adequately tracks data related to 

the intended goals and objectives of the grant. 

2. Ensure Life Span has implemented and disseminated new policies and procedures 

documenting the Deputy Exccu1ive Director's grant-related responsibilities, which includes 

the designation of back-up personnel. 
SUBJECT: Draft Audit Report - Audit of the Office on Violence Against 

Women (OVW) Grant Awarded to Life Span Chicago, Illinois 

Concur: OVW will coordinate with Life Span to ensure that they implement and disseminated 

new policies and proct:dures documenting the Deputy Executive Director's grant-related 

responsibilities, which includes the designation of back-up personnel. 

3. Ensure that Life Span's changes in time and effort and cost allocation methodology 

associated with the senior attorney assigned to the grant is appropriate and acceptable. 

Concur: OVW will coordinate with Life Span to ensure that their changes in time and effort and 

cost allocation methodology associated with the senior attorney assigned to the grant is 

appropriate and acceptable. 

4. Remedy $9,371 in unallowable costs, specifically: 

a. $3,446 in unapproved costs associated with salary expenses; 

b. $775 in pension-related fringe benefits not approved by the OVW; and 

c. $5,150 in unallowable advanced drawdowns. 

Concur: OVW will coordinate with Life Span to ensure that they remedy the $9,371 in 

unallowable costs. 

5. Coordinate with Life Span to ensure that its rent allocation costs are appropriate, 

allowable, and supported. 

Concur: OVW will coordinate with Life Span to ensure that their rent allocation costs are 

appropriate, allowable, and supported. 

6. Ensure that Life Span enhances its process to verify that all expenses identified in the 

accounting system are allocated correctly to the grant prior to drawing down funds. 

Concur: OVW will coordinate with Life Span to ensure that they enhance its process to verify 

that all expenses identified in the accounting system are allocated correctly to the grant prior to 

drawing down funds. 

7. Ensure that Life Span enhances its policies and procedures for preparing and submitting 

FFRs. 

Concur: OVW will coordinate with Life Span to ensure that they enhance its policies and 

procedures for preparing and sub111itting FFRs. 

We appreciate the opportunity to review and comment on the draft report. If you have any 

questions or require additional information, please contact Rodney Samuels at 

(202) 514-9820. 

Page 2 of3 

19 
SUBJECT: Draft Audit Report- Audit of the Office on Violence Against 

Women (OVW) Grant Awarded to Life Span Chicago, Illinois 

cc Louise M. Duhamel, Ph.D. 

Acting Director, Internal Review and Evaluation Office 

Audit Liaison Group, Justice Management Division 

JanSheri Morris 

Program Manager 

Office on Violence Against Women 

Thelma Bailey 

Program Assistant 

Office on Viole11ce Against Women 

Page 3 of3 

20 
 

 

 

 

 

 

APPENDIX 5 

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE AUDIT REPORT 

The OIG provided a draft of this audit report to Life Span and the Office on 

Violence Against Women (OVW) for review and official comment. Life Span’s 

response is incorporated in Appendix 3, and the OVW’s response is incorporated in 

Appendix 4 of this final report. In response to the draft report, Life Span concurred 

with our recommendations. The OVW also concurred with our recommendations, 

and as a result, the status of the report is resolved. The following provides the OIG 

analysis of the responses and summary of actions necessary to close the report. 

Recommendations for the OVW: 

1. Verify that Life Span enhances its performance data collection and 

reporting methodology for progress reports and adequately tracks 

data related to the intended goals and objectives of the grant. 

Resolved. The OVW concurred with our recommendation and stated it will 

coordinate with Life Span to verify that Life Span enhances its performance 

data collection and reporting methodology for progress reports and 

adequately tracks data related to the intended goals and objectives of the 

grant. 

Life Span concurred with our recommendation. Life Span stated that prior to 

the audit, it purchased a new data management system to enhance its data 

collection and reporting abilities. 

This recommendation can be closed when we receive documentation that 

Life Span has enhanced its performance data collection and reporting 

methodologies for progress reports to ensure it is adequately tracking data 

related to the intended goals and objectives of the grant. 

2. Ensure Life Span has implemented and disseminated new policies 

and procedures documenting the Deputy Executive Director’s grantrelated responsibilities, which includes the designation of back-up 

personnel. 

Resolved. The OVW concurred with our recommendation and stated it will 

coordinate with Life Span to ensure that Life Span implements and 

disseminates new policies and procedures documenting the Deputy Executive 

Director's grant-related responsibilities, which includes the designation of 

back-up personnel. 

Life Span also concurred with our recommendation. 

This recommendation can be closed when we receive documentation that 

Life Span has implemented and disseminated new policies and procedures 

21 
 

 

 

 

 

 

 

 

 

 

 

documenting the Deputy Executive Director’s grant-related responsibilities, 

which includes the designation of back-up personnel. 

3. Ensure that Life Span’s changes in time and effort and cost allocation 

methodology associated with the senior attorney assigned to the 

grant is appropriate and acceptable. 

Resolved. The OVW concurred with our recommendation and stated it will 

coordinate with Life Span to ensure that changes in Life Span’s time and 

effort and cost allocation methodology associated with the senior attorney to 

the grant is appropriate and acceptable. 

Life Span concurred with our recommendation. Life Span stated that the OIG 

instructed Life Span officials that the Grant Adjustment Notification (GAN) it 

submitted related to personnel staffing changes should have included 

additional information. For clarification, we provided Life Span with our 

finding that the GAN it submitted for changes in staff did not include specific 

changes in time and effort associated with staffing changes and, therefore, 

the OVW was unaware of these changes. In December 2019, Life Span 

submitted a GAN to the OVW addressing the time and effort and cost 

allocation methodology associated with staff changes. The GAN specifically 

advised the OVW of a staff change associated with Life Span attorneys 

working on the grant; Life Span submitted the resume of the new attorney 

working on the grant and a justification for the change in staffing levels for 

this grant. 

This recommendation can be closed when we receive documentation 

reflecting that the OVW has ensured that Life Span’s changes in time and 

effort and cost allocation methodology associated with the senior attorney 

assigned to the grant is appropriate and acceptable. 

4. Remedy $9,371 in unallowable costs related to salary expenses, 

pension-related fringe benefits, and advanced drawdowns. 

Resolved. The OVW concurred with our recommendation and stated that it 

will coordinate with Life Span to ensure that Life Span remedies the $9,371 

in unallowable costs. 

Life Span concurred with our recommendation. Life Span stated in October 

2019, Life Span submitted a GAN to the OVW to address the unallowable 

costs associated with salary expenses and pension costs. Through this GAN, 

Life Span requested that the OVW retroactively approve Life Span’s 

expenditures associated with salary and fringe benefit costs questioned 

during the audit. However, this GAN does not address the advanced 

drawdowns. 

This recommendation can be closed when we receive documentation 

reflecting that the $9,371 in unallowable costs related to salary expenses, 

22 
 

 

 

 

 

 

 

pension-related fringe benefits, and advanced drawdowns has been remedied 

in an appropriate manner. 

5. Coordinate with Life Span to ensure that its rent allocation costs are 

appropriate, allowable, and supported. 

Resolved. The OVW concurred with our recommendation and stated that it 

will coordinate with Life Span to ensure that Life Span’s rent allocation costs 

are appropriate, allowable, and supported. 

Life Span concurred with our recommendation. Life Span stated that in 

October 2019, Life Span submitted a GAN to the OVW to address the 

changes in its rent costs. Through this GAN, Life Span provided the OVW 

with an overview of the changes it made to its rental allocation methodology 

to account for changes in staffing levels and rental costs associated with its 

new location. 

This recommendation can be closed when we receive documentation 

reflecting that the OVW has ensured that Life Span’s rent allocation costs are 

appropriate, allowable, and supported. 

6. Ensure that Life Span enhances its process to verify that all expenses 

identified in the accounting system are allocated correctly to the 

grant prior to drawing down funds. 

Resolved. The OVW concurred with our recommendation and stated it will 

coordinate with Life Span to ensure that Life Span enhances its process to 

verify that all expenses identified in the accounting system are allocated 

correctly to the grant prior to drawing down funds. 

Life Span also concurred with our recommendation. 

This recommendation can be closed when we receive documentation 

reflecting that Life Span enhanced its process to verify that all expenses 

identified in the accounting system are allocated correctly to the grant prior 

to drawing down funds. 

7. Ensure that Life Span enhances its policies and procedures for 

preparing and submitting FFRs. 

Resolved. The OVW concurred with our recommendation and stated that it 

will coordinate with Life Span to ensure that Life Span enhances its policies 

and procedures for preparing and submitting FFRs. 

Life Span also concurred with our recommendation. 

This recommendation can be closed when we receive documentation 

reflecting that Life Span enhanced its policies and procedures for preparing 

and submitting FFRs. 

23 
 

 

 

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