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REDACTED FOR PUBLIC RELEASE 

LIMITED OFFICIAL USE - PROPRIETARY INFORMATION 

Audit of the Office of Justice Programs 

Victim Compensation Grants Awarded to the 

Massachusetts Department of Attorney General, 

Boston, Massachusetts

AUDIT DIVISION 

20-089 

AUGUST 2020 

REDACTED FOR PUBLIC RELEASE 

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

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

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Executive Summary 

Audit of the Office of Justice Programs Victim Compensation Grants Awarded to the 

Massachusetts Department of Attorney General, Boston, Massachusetts 

Objective 

The objective of the audit was to evaluate how the 

Massachusetts Department of Attorney General, Victim 

Compensation and Assistance Division (VCAD) designed 

and implemented its crime victim compensation 

program. To accomplish this objective, we assessed 

performance in the following areas of grant 

management: (1) grant program planning and 

execution, (2) program requirements and performance 

reporting, and (3) grant financial management. 

Results in Brief 

As a result of our audit, we concluded that VCAD used 

its grant funds to compensate crime victims. This audit 

did not identify significant concerns with VCAD’s federal 

financial reports or drawdowns. However, we identified 

several opportunities where VCAD could improve its 

performance reporting as well as implement and adhere 

to procedures for its annual state certification form. We 

also identified areas of concern related to claim 

processing and the timeliness of victim compensation 

payments. Finally, we identified several errors during 

our review of victim compensation claims and 

administrative expenditures, which resulted in $27,929 

in questioned costs. 

Recommendations 

Our report contains six recommendations to the Office of 

Justice Programs to improve VCAD’s grant management 

and remedy questioned costs. We requested a response 

to our draft audit report from the VCAD and OJP, which 

can be found in Appendix 3 and 4, respectively. Our 

analysis of those responses is included in Appendix 5. 

Audit Results 

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

General completed an audit of two Victims of Crime Act 

(VOCA) victim compensation formula grants awarded by 

the Office of Justice Programs, Office for Victims of 

Crime (OVC) to the Department of Attorney General in 

Boston, Massachusetts. The OVC awarded these 

formula grants, totaling $2,726,000 from fiscal 

years (FY) 2016 to 2017 from the Crime Victims Fund to 

provide financial support through the payment of 

compensation benefits to crime victims throughout 

Massachusetts. As of February 2020, VCAD drew down 

a cumulative amount of $2,718,557 for all of the grants 

we reviewed. 

Program Accomplishments – VCAD enhanced 

services for crime victims by outreach efforts to increase 

public awareness of available benefits and by 

appropriately distributing the VOCA funding it received. 

Claim Processing Time – While we found that VCAD 

had an established process for the intake, review, and 

payment or denial of individual compensation claims, we 

determined that VCAD’s current claim process is 

ineffective and inefficient at providing timely 

reimbursement to victims of crime. 

Performance Reporting – We were able to reconcile 

all of the information reported to the OVC in VCAD’s 

quarterly reports. However, we identified a significant 

discrepancy in the narrative portion of its annual reports 

related to claim processing time. 

Claim and Administrative Expenditures – We 

determined that most of the expenditures we reviewed 

were allowable and supported. However, we did identify 

several errors during our review of both the victim 

compensation claims and administrative expenditures, 

which resulted in $27,929 in questioned costs. 

State Certification Forms – We determined VCAD did 

not ensure that it correctly calculated the amounts 

reported on its annual certification forms, did not 

maintain supporting documentation, and lacked policies 

and procedures for completion of the state certification 

form. 

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AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

VICTIM COMPENSATION GRANTS AWARDED TO THE 

MASSACHUSETTS DEPARTMENT OF ATTORNEY GENERAL, 

BOSTON, MASSACHUSETTS 

TABLE OF CONTENTS 

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

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

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

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

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

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

Annual State Certification ............................................................ 5 

Program Requirements and Performance Reporting .................................. 6 

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

Compliance with Special Conditions ............................................... 8 

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

Grant Expenditures ..................................................................... 9 

Drawdowns.............................................................................. 14 

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

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

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

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

APPENDIX 3: MASSACHUSETTS DEPARTMENT OF ATTORNEY GENERAL 

RESPONSE TO THE DRAFT AUDIT REPORT............................................. 19 

APPENDIX 4: OFFICE OF JUSTICE PROGRAMS RESPONSE TO THE DRAFT 

REPORT............................................................................................ 22 

APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT .................................. 26 
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AUDIT OF THE OFFICE OF JUSTICE PROGRAMS

VICTIM COMPENSATION GRANTS AWARDED TO THE

MASSACHUSETTS DEPARTMENT OF ATTORNEY GENERAL, 

BOSTON, MASSACHUSETTS

INTRODUCTION

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

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

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

Massachusetts Department of Attorney General (DAG) in Boston, Massachusetts. 

The OVC awards victim compensation grants annually from the Crime Victims Fund 

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

2016 through 2017, these OVC grants totaled $2,726,000. 

Table 1 

Audited Grants

Fiscal Years 2016 – 2017

Award Number Award Date Award Period 

Start Date

Award Period 

End Date Award Amount

2016-VC-GX-0020 8/17/2016 10/1/2015 9/30/2019 $1,431,000

2017-VC-GX-0060 9/28/2017 10/1/2016 9/30/2020 1,295,000

Total: $ 2,726,000

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

Source: OJP

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

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

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

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

proceeds from the CVF to states and territories. VOCA victim compensation 

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

to eligible recipients.

The primary purpose of the victim compensation grant program is to 

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

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

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

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

attributable to a death resulting from a compensable crime.2

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

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

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Grantee 

As the Massachusetts state administering agency, the DAG was responsible 

for administering the VOCA victim compensation program. According to its website, 

the DAG is committed to empowering crime victims and providing them with the 

tools and support they need to begin the healing process. Within the DAG, the 

Victim Compensation and Assistance Division (VCAD) handles the day-to-day 

administration and oversight of the victim compensation VOCA grants. VCAD 

provides financial assistance to eligible victims of violent crime for uninsured 

medical and dental care, mental health counseling, funeral and burial costs, and 

income lost due to the inability to work, amongst other expenses. 

OIG Audit Approach 

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

implemented its crime victim compensation program. To accomplish this objective, 

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

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

reporting, and (3) grant financial management. 

We tested compliance with what we considered the most important 

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

authorizing VOCA legislation, the VOCA compensation program guidelines (VOCA 

Guidelines), DOJ Grants Financial Guide, the General Laws of Massachusetts: 

Chapter 258C, 940 CMR 14.00 (the Massachusetts Compensation of Victims of 

Violent Crimes), and the Victim Compensation Administrative Manual as our 

primary criteria. We reviewed relevant VCAD policies and procedures and 

interviewed VCAD personnel to determine how VOCA funds were administered. We 

also reviewed VCAD records reflecting grant activity.3 Additionally, we assessed 

VCAD’s internal controls, implemented at the time of our audit, specific to its 

design, implementation, and operating effectiveness for those internal controls we 

deemed significant within the context of our audit objective. 

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

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

schedule of our dollar-related findings. 

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AUDIT RESULTS 

Grant Program Planning and Execution 

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

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

we assessed VCAD’s overall process for making victim compensation payments. 

We assessed VCAD’s policies and procedures for providing compensation payments 

to victims, as well as the accuracy of the state certification forms. 

Program Implementation 

State administering agencies receive VOCA victim compensation grants to 

compensate victims for expenses incurred from criminal victimization. As the state 

administering agency for Massachusetts, the VCAD was responsible for the victim 

compensation program, including meeting all financial and programmatic 

requirements. When paying claims for victims, VCAD operated under the 

Massachusetts Compensation of Victims of Violent Crimes and the Victim 

Compensation Administrative Manual, which conveyed the state-specific policies for 

the victim compensation program. In assessing VCAD’s implementation of its 

victim compensation program, we analyzed policies and procedures governing the 

decision-making process for individual compensation claims, as well as what efforts 

VCAD had made to bring awareness to victims eligible for compensation program 

benefits. 

Overall, we determined that VCAD’s implementation of its victim 

compensation program was appropriate and in compliance with the VOCA 

Guidelines and the terms and conditions of the grants we audited. We found that 

VCAD had an established process for the intake, review, and payment or denial of 

individual compensation claims, and that VCAD had adequate separation of duties 

between the employees who reviewed the claims and the employee who authorized 

payment. However, we determined that the current claim process was ineffective 

and inefficient at providing timely payments to claimants. We also identified 

several issues with the accuracy of VCAD’s annual state certification forms, 

including a lack of policies and procedures for completing the form. 

New Policy 

The Massachusetts legislature amended the Victims of Violent Crime statute 

(M.G.L. c258C) allowing VCAD to compensate specifically for funeral and burial 

expenses in cases where there is evidence of contributory conduct on the part of 

the deceased victim. This change has been in effect since April 13, 2018. 

Previously, contributory conduct on the part of the deceased victim could make a 

claim ineligible or eligible at 50 percent for all expenses allowed under the Program. 

Now VCAD can issue compensation for the verified funeral and burial expenses 

associated with these claims. However, VCAD cannot provide compensation for 

other types of expenses in these cases. 

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Public Outreach 

We found that VCAD made efforts to enhance public awareness of available 

victim compensation benefits through outreach efforts that included training efforts 

and an annual Victim Rights Awareness calendar that is distributed to local and 

state police departments, advocate agencies, college campuses, hospitals, and 

funeral homes. 

Claim Processing Time 

VCAD staffing is primarily comprised of a Director, Deputy Director, an 

Intake Assistant, two Eligibility and Outreach Coordinators, and three 

Investigators. New applications for compensation are received and date-stamped 

by the Intake Assistant, who later reviews each application for completeness of 

information. The Intake Assistant requests a police report or other investigative 

checklist for each claim. 

Once a police report is received, general claims go to the Eligibility and 

Outreach Coordinators for review and assessment of eligibility, except for homicide 

and Forensic Sexual Assault Examinations, which are expedited. The Eligibility and 

Outreach Coordinators review the police reports obtained in the intake process. If 

the claim is determined eligible, the initial eligibility letters are sent to the claimant 

and the claim is then filed for assignment by the Deputy Director. 

Twice a month, the Deputy Director assigns eligible claims for investigation. 

The Investigator sends a Request for Information letter to the claimant that 

includes a checklist of items specific to their claim that are required for an award to 

be made. The Investigator reviews all bills, receipts, information, and verifies 

balances and dates of crime-related services, and sends appropriate verifications to 

providers, employers, funeral homes, Social Security, etc. 

When an investigation is complete, the Investigator enters all submitted 

expenses into the case management system as approved or denied and forwards 

the claim with an Investigative Report to the Deputy Director for review and 

issuance of Notice of Award or Notice of Denial of Expenses. The Deputy Director 

reviews the expenses and updates the database with the resolution and the 

resolution date. If expenses are approved, a Notice of Award is sent to the 

claimant with a Notice of Assent for signature. 

According to the VCAD Director, it takes approximately 6 to 8 months, on 

average, for VCAD to determine claim eligibility for general claims. As shown in 

Table 2, based on our review of VCAD case management system data, we found 

that the average amount of time it takes to determine claim eligibility was 8 

months. Additionally, we found that it takes approximately 12 months, on average, 

for a general claim to receive its first payment. For expedited claims, such as 

homicide and Forensic Sexual Assault Examinations, the timeframe is much shorter, 

with an average of 3 months from claim processing to first payment. 

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Table 2 

Average Claim Processing Time for General and Expedited Claims 

Fiscal Years 2016 – 2019 

Months General Claims Expedited Claims 

0-2 Intake 

Eligibility 

2-4 

Application Received 

Investigation 

First Payment 

4-6 

Intake 

6-8 

8-10 Eligibility 

10-12 Investigation 

First Payment 

Source: OIG Analysis 

VCAD currently operates on a “lag” in its review of compensation claim files. 

For example, applications submitted in January move to investigation generally in 

September of the same year. We asked VCAD officials why the claims process is so 

lengthy. According to the VCAD Director, obtaining documentation, such as the 

police report (during Intake), bills (during Investigation), or the signed Notice of 

Assent (after Investigation), can each take several months, if not longer. 

While we found that VCAD had an established process for the intake, review, 

and payment or denial of individual compensation claims, and that VCAD had 

adequate separation of duties between the employees who reviewed the claims and 

the employee who authorized payments, we determined that VCAD’s current claim 

process is ineffective and inefficient at providing timely reimbursement to victims of 

crime. In our view, it is unreasonable to delay benefits to eligible claimants as 

crime victims may be struggling through financial hardship due to costs associated 

with the crime in addition to having to deal with the non-financial issues associated 

with the crime, and more timely payment may reduce such hardships. Therefore, 

we recommend that OJP work with VCAD to reevaluate their established process for 

claim processing to ensure timely reimbursement to victims of crime. 

Annual State Certification 

State administering agencies must submit an annual Crime Victim 

Compensation State Certification Form, which provides OVC the necessary 

information to determine future annual grant award amounts. The certification 

form must include all sources of revenue to the crime victim compensation program 

during the federal fiscal year, as well as the total of all compensation claims paid to, 

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

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

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

prior.4 The accuracy of the information provided in the certification form is critical 

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

each state. 

We assessed VCAD’s controls for preparing the annual certification forms 

submitted to the OVC for FYs 2015 through 2018, which was used to calculate the 

award amounts granted in FYs 2017 through 2020.5 We were told that the Deputy 

Budget Director prepared and the VCAD Director reviewed the certification forms. 

According to the Deputy Budget Director, VCAD did not have any written policies 

and procedures for preparing the certifications at the time of our audit. In addition, 

the Deputy Budget Director informed us that VCAD did not maintain supporting 

documentation for certifications they prepared and that they were unable to 

recreate precise financial data extracted from existing accounting records and 

reconcile the figures reported in the certification forms submitted for the periods. 

For our review, we used existing accounting records that the Deputy Budget 

Director produced in an effort to reconcile the reports. We also used additional 

supporting documentation from VCAD’s case management system to review 

support for loss of property. 

We attempted to reconcile the category amounts reported on the four annual 

certification forms we reviewed, but we could not verify most of them, including the 

amounts for refunds, restitution, and subrogation. When asked about these 

discrepancies, the Deputy Budget Director admitted that refunds and restitutions 

were not always sent to the same office within the DAG, which causes the amounts 

for refunds and restitutions to not always be accurately recorded. 

We determined VCAD did not ensure that it correctly calculated the amounts 

reported on its annual certification forms. Based on our analysis, we could not 

determine if the unsupported amounts resulted in over or underreporting. As 

mentioned earlier, the accuracy of the information provided in the certification form 

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

granted to each state. Therefore, we recommend that OJP ensure VCAD 

implements and adheres to comprehensive written policies and procedures to 

ensure its certification forms are accurate, and supporting documentation is 

maintained to facilitate review and audit of funds awarded. 

Program Requirements and Performance Reporting 

To determine whether VCAD distributed VOCA victim compensation program 

funds to compensate victims of crime, we reviewed VCAD performance measures 

and performance documents that VCAD used to track goals and objectives. We 

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

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

property loss, and other reimbursements. 

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

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

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further examined OVC solicitations and award documents and verified VCAD 

compliance with special conditions governing recipient award activity. 

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

performance reporting, we believe that VCAD: (1) implemented adequate 

procedures to compile annual performance reports, and (2) complied with tested 

special conditions. However, we did identify a significant discrepancy related to a 

statistic reported in the annual performance report narrative. 

Annual Performance Reports 

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

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

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

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

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

Administering Agencies, responsible for managing CVF awards, are required to 

produce the Annual State Performance Report and upload it to GMS. 

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

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

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

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

compensation paid by service type. 

We assessed whether VCAD’s annual performance report to OVC accurately 

reflected the performance figures of the victim compensation program. VCAD used 

its electronic case management system to prepare its quarterly performance 

reports. To assess VCAD’s performance, we compared the case management 

reports maintained quarterly by VCAD to its FY 2016 and FY 2017 quarterly 

performance reports submitted to OVC. We also sampled and tested metrics from 

every applicable metric category in the performance report, as listed above. 

Finally, we tested one statistic discussed in the narrative portion of the annual 

performance reports from FY 2016 through 2018 related to claim processing time. 

Based on our review, we were able to reconcile all of the information 

reported to the OVC in VCAD’s quarterly reports. VCAD also maintained supporting 

documentation for each of the figures reported in its quarterly performance reports. 

However, we were unable to reconcile a statistic reported in the narrative section in 

each of its annual performance reports, described below. 

In the narrative section of the annual report, OVC asks states to provide the 

average length of time, in days, it takes to process an application for claim eligibility 

for compensation. VCAD reported 21 days in FY 2016, 19 days in FY 2017, and 

37 days in FY 2018. We asked the VCAD Director about these reported numbers, 

and the VCAD Director explained that the figures provided in its annual reports 

represented the number of weeks as opposed to days, despite what the 

performance report stated. In addition to this error, our analysis of VCAD case 

management data found that the average claim processing time, which included 

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both general and expedited claims, was approximately 17 weeks (117 days) in 

FY 2016, 22 weeks (152 days) in FY 2017, and 12 weeks (88 days) in FY 2018. We 

believe that these discrepancies are significant, as seen in Table 3, and 

misreporting such performance data prevents OVC from properly monitoring how 

VOCA funds are handled. 

Table 3

Average Claim Processing Time

Annual PMT Fiscal Years 2016 – 2018

Fiscal Year VCAD Reported

(in Days) 

Supporting 

Documentation 

(in Days)

Difference 

(in Days) 

2016 21 117 96

2017 19 152 133

2018 37 88 51

Source: OIG Analysis

We recommend that OJP ensure VCAD reviews and accurately reports all 

performance data so that OVC can properly monitor how VOCA funds are handled

and spent. 

Compliance with Special Conditions

The special conditions of a federal grant award establish specific 

requirements for grant recipients. In its grant application documents, VCAD 

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

conditions for each VOCA victim compensation program grant and identified special 

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

addressed in another section of this report. We judgmentally selected the following 

four special conditions to review in greater detail:

1. Ensure that at least one key grantee official attends the annual VOCA 

National Training Conference.

2. Comply with applicable requirements regarding the System for Award 

Management (SAM), to include registering for a SAM account and 

maintaining the currency of information in the system.

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

must have successfully completed the OJP Financial Management and 

Grant Administration Training.

4. Collect information regarding race, sex, and age of recipients of 

compensation benefits, where such information is voluntarily furnished.

We found that VCAD complied with all of the special conditions we reviewed 

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Grant Financial Management 

Award recipients must establish an adequate accounting system and 

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

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

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

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

resulting financial reports. To further evaluate VCAD’s financial management of the 

VOCA victim compensation grants, we also reviewed the Single Audit Report for 

FY 2018. We also interviewed VCAD personnel who were responsible for financial 

aspects of the grants, reviewed VCAD’s written policies and procedures, inspected 

award documents, and reviewed financial records. 

As discussed below, in our overall assessment of grant financial 

management, we determined that VCAD generally implemented adequate controls 

over claim payments and administrative expenditures associated with managing the 

victim compensation program. We also did not identify significant deficiencies 

related to VCAD’s process for developing drawdown requests and determined that it 

reported quarterly Federal Financial Reports accurately. However, during our 

testing of grant expenditures, we identified $27,929 in unsupported claim expenses 

and an immaterial amount of unallowable administrative expense. 

Grant Expenditures 

State administering agency VOCA compensation expenses fall into two 

overarching categories: (1) compensation claim payments – which constitute the 

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

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

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

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

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

transactions. We also tested a sample of denied claims to ensure VCAD adequately 

adjudicated each claim in accordance with state policies and VOCA Guidelines. 

Based on our testing, we determined that most of the expenditures we reviewed 

were allowable, supported by adequate documentation, and approved in accordance 

with state policies and VOCA Guidelines. However, we identified several errors 

during our review of the victim compensation claims and administrative 

expenditures. 

Victim Compensation Claim Expenditures 

Victims of crime in the Commonwealth of Massachusetts submit claims for 

reimbursement of expenses incurred as a result of victimization, such as medical 

and funeral costs, loss wages, and loss of financial support. VCAD staff adjudicate 

these claims for eligibility and make payments from the VOCA victim compensation 

grants and state funding. 

To evaluate VCAD’s financial controls over VOCA victim compensation grant 

expenditures, we reviewed victim compensation claims to determine whether the 

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payments were accurate, allowable, timely, and in accordance with the policies of 

the VOCA Guidelines, the Massachusetts Compensation of Victims of Violent Crimes, 

and the Victim Compensation Administrative Manual. We judgmentally selected 

15 claims, associated with 87 transactions, totaling approximately $343,000. The 

transactions we reviewed included costs in the following categories: medical, 

funeral, mental health, lost wages, loss of support, forensic sexual assault exam, 

homemaker expenses, and catastrophic injury.6 

• Loss of Financial Support 

We reviewed a claim for loss of financial support to an eligible dependent of a 

deceased victim. According to the Massachusetts Victim Compensation 

Administrative Manual, in order to determine how an award is calculated, VCAD 

must first determine the nature of the dependency of the claimant as either fully 

dependent or partially dependent on the victim. According to VCAD’s policy, full 

dependency is defined as when a claimant is wholly supported by the victim’s 

income, while partial dependency is when the claimant either receives some direct 

financial support from the victim or is the beneficiary of court ordered support paid 

by the victim. VCAD policy further states that loss of financial support awards are 

calculated based on the financial support provided by the victim to the dependent, 

multiplied by the number of years for which the dependent would have remained 

financially dependent on the victim. 

Additionally, in the case of dependents of homicide victims in Massachusetts, 

VCAD current policy classifies this as a catastrophic injury which entitles a 

claimant’s allowable expenses to be compensated up to $50,000. According to 

VCAD’s policy, when a claim is classified as a catastrophic injury, the eligible payout 

increases to a maximum of $50,000, or double the $25,000 maximum payment 

amount for non-catastrophic claims. 

The claim we reviewed involved an eligible dependent claimant who, at the 

time of the crime, was 18 years old, but had a court order which stated the victim 

was to provide weekly child support up until the claimant reached the age of 21. 

Based on our review of the claim supporting documentation, we determined the 

claimant was partially dependent on the victim; however, Massachusetts calculated 

the award amount as if the claimant was fully dependent, and used the victim’s 

earnings to determine the award amount of $34,746. We discussed this claim with 

officials who stated that upon further review of the documents in the file, the 

information demonstrated that the claimant was partially dependent upon the 

victim at the time of the crime, and the calculations of the loss of financial support 

were in error and should have been based on the court documented amount of child 

6 According to VCAD policy, homemaker expenses may be awarded if the sole occupation of 

the victim at the time of the crime, and for 1 year preceding the crime, was limited to performing the 

duties and responsibilities of a homemaker, and if, as a direct result of injuries from the crime, the 

victim is disabled from continuing to provide some or all of the duties and responsibilities of a 

homemaker. Homemaker services include housekeeping, shopping, errands, meal preparation, 

laundry, and supervision of children. 

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support. Because of this error, the claimant received $27,402 more than should 

have been awarded. 

• Lost Wages 

We also reviewed a claim where the claimant sought compensation for lost 

wages. According to the Massachusetts Victim Compensation Administrative 

Manual, to be eligible for lost wages, the claimant must demonstrate that they are 

disabled from working as a direct result of the crime. VCAD requested that the 

employer complete an Employment Verification Form verifying that the claimant 

was working at the time of the crime, to provide their net and gross salary, any 

used vacation, sick, or personal time during their crime related period of disability, 

as well as the receipt of any collateral benefits including, but not limited to, shortterm or long-term disability, paid wages, or unemployment benefits. 

For the claim we reviewed, the claimant’s award for lost wages was based on 

the claimant’s net weekly salary at the time of the crime. The victim’s employer 

paid short-term disability for 13 weeks and long-term disability, at a reduced rate 

of 60 percent, for an additional 11 weeks. Based on our review, for the 11 weeks 

the victim received long-term disability, the claim payment should have been 

reduced to 40 percent. We discussed this issue with VCAD officials, and they 

concurred that the calculation was an error. Because of this error, the victim 

received $527 more than should have been awarded. 

As a result of these errors identified in the tested loss of financial support 

and lost wage claims, we question the costs associated with the unsupported 

amounts. We recommend that OJP remedy the $27,929 in unsupported 

expenditures. 

Denied Claims 

We judgmentally selected five denied claims to review. To assess whether 

the documentation maintained in VCAD’s case files adequately supported its 

decision to deny claims, we reviewed available documentation including the 

application for benefits, the police report from the law enforcement agency, and 

any other supporting documentation. Based on our review, we determined that the 

documentation maintained by VCAD adequately supported its decision to deny each 

of the five claims. 

Administrative Expenditures 

State administering agencies may retain up to 5 percent of each grant to pay 

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

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

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

outreach. For the compensation grant program, we tested VCAD’s compliance with 

the 5 percent limit on the administrative category of expenses, as shown in Table 4. 

11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 4 

Administrative Expenditures 

Award NumberTotal Award 

State 

Administrative 

Expenditures 

Administrative 

Percentage 

2016-VC-GX-0020 $1,431,000 $37,290 2.6% 

2017-VC-GX-0060 $1,295,000 $38,479 3% 

Source: OIG Analysis 

We found that VCAD’s administrative expenses did not exceed 5 percent of 

their total award. We compared the total administrative expenditures charged to 

the grants against the general ledger report derived from VADC’s accounting 

system and determined that the state has complied with these limits. 

In addition to assessing VCAD’s compliance with the 5 percent administrative 

allowance threshold, we tested a sample of administrative expenditures to ensure 

these were allowable and supported by adequate documentation. Based on our 

analysis, VCAD used its administrative expenditures to pay personnel, indirect 

costs, travel for training, and public outreach. We judgmentally sampled 12 expenses, 

totaling approximately $9,000, charged to the grant from each of these categories. 

Based on our testing, we determined VCAD generally charged the grant for 

allowable expenses that were adequately supported; however, we did find one 

charge, for DAG office furniture, that was unallowable. According to the VCAD 

Director, this charge was the result of an administrative oversight that should have 

been detected. While the amount charged to the grant was immaterial, we still 

believe that a more robust policy would have prevented this unallowable expense. 

Therefore, we recommend that OJP ensure VCAD implement and adhere to written 

policies and procedures for processing administrative expenses that would prevent 

such unallowable expenses charged to the grant. 

Crowdfunding 

In its Notice of Assent letter, Massachusetts informs claimants of their “Duty 

to Notify [VCAD] about Payments from Other Sources.” It states that if a claimant 

receives future payments resulting from the crime from any other source, including 

from the offender (restitution), insurance, civil lawsuit, or other payment source, 

the claimant is required by law to notify VCAD of the receipt of such payments. If 

the total payments exceed the actual losses, the claimant may be required to 

reimburse Massachusetts for some or all of the compensation award. This Notice of 

Assent Letter is signed by all claimants who receive an award from the 

Commonwealth. 

During our claim expenditure testing, we sampled several claims that 

involved Boston Marathon bombing victims. From our audit research we 

determined that all of the victims’ claims we reviewed had crowdfunding accounts 

established in their names. Most of the crowdfunding accounts we viewed received 

12 
 

 

 

 

 

 

 

 

 

 

 

 

hundreds of thousands of dollars and requested donations for the victims’ growing 

medical expenses, lost wages, or travel for medical or mental health appointments. 

We asked VCAD if it had any policies regarding crowdfunding platforms and 

whether such sources of funding were included in making claim determinations. 

The VCAD Director informed us that all compensable expenses of Boston Marathon 

victims were vetted by VCAD, including whether there were any other third-party 

sources of payment prior to compensation of any compensable expenses. The 

VCAD Director added that this is in addition to their signed statement from the 

Notice of Award. Additionally, the VCAD Director noted that Massachusetts did not 

have any policies related to crowdfunding platforms and had not received any 

guidance from OJP on the matter. 

We discussed crowdsourcing funds with OJP and found that no official 

guidance has been released to State Administering Agencies about crowdfunding 

platforms. An attorney from the OJP Office of the General Counsel pointed out that 

the statutory provision that makes a state victim compensation program the “payer 

of last resort” applies only to “costs that a Federal program... or a Federally 

financed State or local program, would otherwise pay,” and does not apply to 

crowdfunding accounts or require that crowdfunding be exhausted before the state 

compensation program may pay expenses. 

Because of the lack of guidance provided to states for crowdfunding 

platforms and the various uncertainties on how to handle such funds, we 

recommend that OJP inform all State Administering Agencies (SAAs) nationwide of 

the applicable VOCA Compensation Program requirements regarding crowdfunding 

and develop appropriate resources to assist SAAs in addressing how crowdfunding 

affects victim compensation. 

13 
 

 

 

 

 

 

 

 

 

 

Drawdowns 

Award recipients should request funds based upon immediate disbursement 

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

ensure that the federal cash on hand is the minimum needed for disbursements or 

reimbursements made immediately or within 10 days. VOCA victim compensation 

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

years. To assess whether VCAD managed grant receipts in accordance with these 

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

expenditures in VCAD’s accounting system and accompanying financial records. 

For the VOCA victim compensation awards, VCAD automatically draws down 

funds on a weekly basis based on expenditures in its accounting system. Table 5 

shows the total amount drawn down for each grant as of February 12, 2020. 

Table 5 

Amount Drawn Down for Each Grant as of February 12, 2020 

Award Number Total Award Award Period 

End Date 

Amount 

Drawn Down 

Amount 

Remaining 

2016-VC-GX-0020 $1,431,000 09/30/2019 $1,431,000 $0 

2017-VC-GX-0060 $1,295,000 09/30/2020 $1,287,557 $7,443 

Total: $2,726,000 $2,718,557 $7,443 

Source: OJP Payment History Reports 

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

recipient’s process for developing drawdown requests. However, we identified 

deficiencies and questioned costs related to compliance of individual expenditures 

with grant requirements, as described in the Grant Expenditures sections above. 

Financial Reporting 

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

actual expenditures and unliquidated obligations incurred for the reporting period 

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

VCAD submitted accurate Federal Financial Reports, we compared all the reports 

due as of September 30, 2019, to its accounting records for each grant. We 

determined that quarterly and cumulative expenditures for the reports reviewed 

matched the accounting records. 

14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

CONCLUSION AND RECOMMENDATIONS 

We found that VCAD used its grant funds to compensate eligible crime 

victims in accordance with the criteria governing the VOCA victim compensation 

program. We did not take issue with VCAD’s federal financial reports or 

drawdowns. However, we identified several opportunities where VCAD could 

improve its performance reporting as well as implement and adhere to procedures 

for its annual state certification form. We identified an area of concern related to 

claim processing and the timeliness of victim compensation payments. We also 

identified several errors during our review of victim compensation claim and 

administrative expenditures. We provide six recommendations to OJP to address 

these deficiencies. 

We recommend that OJP: 

1. Work with VCAD to reevaluate their established process for claim processing 

to ensure timely reimbursement to victims of crime. 

2. Ensure VCAD implements and adheres to comprehensive written policies and 

procedures to ensure its annual state certification forms are accurate, and 

supporting documentation is maintained to facilitate review and audit of 

funds awarded. 

3. Ensure VCAD reviews and accurately reports all performance data so that 

OVC can properly monitor how VOCA funds are handled and spent. 

4. Remedy the $27,929 in unsupported expenditures. 

5. Ensure VCAD implement and adhere to written policies and procedures for 

processing administrative expenses that would prevent such unallowable 

expenses charged to the grant. 

6. Inform all SAAs nationwide of the applicable VOCA Compensation Program 

requirements regarding crowdfunding and develop appropriate resources to 

assist SAAs in addressing how crowdfunding affects victim compensation. 

15 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 1 

OBJECTIVE, SCOPE, AND METHODOLOGY 

Objective 

The objective of the audit was to evaluate how the Massachusetts 

Department of Attorney General (DAG) designed and implemented its crime victim 

compensation program. To accomplish this objective, we assessed performance in 

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

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

financial management. 

Scope and Methodology 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require that we plan and 

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

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

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

based on our audit objective. 

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

formula grants 2016-VC-GX-0020 and 2017-VC-GX-0060 from the Crime Victims 

Fund awarded to the DAG. The Office of Justice Programs (OJP), Office for Victims 

of Crime (OVC) awarded these grants totaling $2,726,000 to the DAG, which serves 

as the state administering agency. Within the DAG, the Victim Compensation and 

Assistance Division (VCAD) handles the day-to-day administration and oversight of 

the victim compensation VOCA grants. Our audit concentrated on, but was not 

limited to, the period of October 1, 2015, the project start date for VOCA 

compensation grant number 2016-VC-GX-0020, through March 2020. As of 

February 2020, VCAD had drawn down a total of $2,718,557 from the two audited 

grants. 

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

be the most important conditions of VCAD’s activities related to the audited grants, 

which included conducting interviews with Commonwealth of Massachusetts 

financial staff, examined policies and procedures, and reviewed grant 

documentation and financial records. We performed sample-based audit testing for 

grant expenditures including payroll and fringe benefit charges, financial reports, 

progress reports. In this effort, we employed a judgmental sampling design to 

obtain broad exposure to numerous facets of the grants reviewed. This 

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

universe from which the samples were selected. The authorizing VOCA legislation, 

the VOCA compensation program guidelines, the DOJ Grants Financial Guide, the 

General Laws of Massachusetts: Chapter 258C, 940 CMR 14.00, and the award 

documents contain the primary criteria we applied during the audit. 

16 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

System as well as VCAD’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 

was verified with documents from other sources. 

Internal Controls 

In this audit, we performed testing of internal controls significant within the 

context of our audit objectives. We did not evaluate the internal controls of VCAD 

to provide assurance on its internal control structure as a whole. VCAD management 

is responsible for the establishment and maintenance of internal controls in 

accordance with 2 C.F.R. §200. Because we do not express an opinion on VCAD’s 

internal control structure, we offer this statement solely for the information and use 

of VCAD and OJP.7 

In planning and performing our audit, we identified the following internal 

control components and underlying internal control principles as significant to the 

audit objective: 

Internal Control Components & Principles Significant to the Audit Objectives 

Control Activity Principles 

Management should design control activities to achieve objectives and respond to risks. 

Management should design the entity’s information system and related control activities to 

achieve objectives and respond to risks. 

Management should implement control activities through policies. 

Information & Communication Principles 

Management should use quality information to achieve the entity’s objectives. 

We assessed the design, implementation, and/or operating effectiveness of 

these internal controls implemented at the time of our audit and identified 

deficiencies that we believe could affect the VCAD’s ability to effectively and 

efficiently operate, to facilitate reporting of accurate state financial performance 

information, and to ensure compliance with laws and regulations. The internal 

control deficiencies we found are discussed in the Audit Results section of this 

report. However, because our review was limited to aspects of these internal 

control components and underlying principles, it may not have disclosed all internal 

control deficiencies that may have existed at the time of this audit. 

7 This restriction is not intended to limit the distribution of this report, which is a matter of 

public record. 

17 
 

 

 

 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

Description Amount Page 

Questioned Costs:8 

Unsupported Costs – Claim Review $27,929 

TOTAL DOLLAR-RELATED FINDINGS $27,929 

11 

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

contractual requirements; are not supported by adequate documentation at the time of the audit; or 

are unnecessary or unreasonable. Questioned costs may be remedied by offset, waiver, recovery of 

funds, the provision of supporting documentation, or contract ratification, where appropriate. 

18 
 

 

APPENDIX 3 

MASSACHUSETTS DEPARTMENT OF ATTORNEY GENERAL 

RESPONSE TO THE DRAFT AUDIT REPORT 

19 

COMMONWEALTH OF MASSACHUSETTS 

OFFICE OF THE ATTORNEY GENERAL 

ONEASHBURTONPLACE 

BOSTON, MASSACHUSETTS 02108 

MAURA HEALEY 

ATTORNEY G ENERAL 

(6 17) 727-2200 

(617) 727-4765 TTY 

www.mass.gov/ago 

June 30, 2020 

Thomas O. Puezer 

Regional Audit Manager 

Philadelphia Regional Audit Office 

Office of the Inspector General 

United States Department of Justice 

701 Market Street, Suite 2300 

Philadelphia, PA 19106 

VIA: Electronic Mail at: Thomas.0.Puerzer@usdoj.gov 

Re: Response to Audits 2016-VC-GX-0020 and 2017-VC-GX-0060 

Dear Mr. Puezer: 

The Massachusetts Attorney Generals' Office (AGO) Victim Compensation and 

Assistance Division (VCAD) is in receipt of the draft audit report dated June 9, 2020. On behalf 

of Attorney General Maura Healey, we are grateful for the cooperation of your office and staff 

demonstrated to our team durino the audit process. Specifically, we'd like to thank_, 

and for their time, effort and careful attention during this 

review. 

The audit process provides VCAD with the opportunity to strengthen our program and 

make necessary changes to ensure that victims of violent crime in Massachusetts are provided 

with the best compensation program possible. As a critical financial assistance program for 

victims of violent crime, it is imperative that we continue to build upon this vital source of 

assistance for the survivors of violent crime. 

We have had the opportunity to review the draft report and submit the following 

comments for your review. 
ecommendation #1: OJP to work with VCAD to reevaluate their established process for claim 

processing to ensure timely reimbursement to victims of crime. 

Response #1: We agree with the recommendation and will assess each stage of our review 

process to ensure the timely processing of claims and reimbursements. This will include more 

specific timefi-a,nesfor eligibility decision-making in claims where limited law enforcement 

information is available. Updates to our processes will be reviewed by the AGO 's Executive 

Bureau and discussed with OJP. 

While VCAD will continue to look.for ways to reduce the claims process time, it should be noted 

that not all delays are within the purview of the division. For example, one significant and 

reoccurring delay is the time it takes to receive the police reportj,,-om the pertinent local police 

department. VCAD is considering ways to address this issue, within the confines of the 

authorizing statute and regulations. Additionally, delays in processing expenses may also be the 

result of unsubmitted expenses by the claimant that could, in fact, be eligible for reimbursement. 

Recommendation #2: OJP will ensure VCAD implements and adheres to comprehensive written 

policies and procedures to ensure its annual state certification forms are accurate, and supporting 

documentation is maintained to facilitate review and audit of funds awarded. 

Response #2: We agree with this recommendation and VCAD will work with our Budget Division 

to ensure that all data submitted is reviewed and reconciled p rior to the submission of the annual 

state certification form. 

It is our understanding that clear and accurate compliance with the state certification p rocess is 

not limited to Massachusetts. Should OJP, or others, be considering ways to help promote 

consistency in filing, our team would welcome the support. 

Recommendation #3: OJP will ensure VCAD reviews and accurately reports all performance 

data so that OVC can properly monitor how VOCA funds are handled and spent. 

Response #3: We agree with this recommendation and will develop an internal policy of how 

data is collected and maintained for the quarterly PMT reports. Specifically, VCAD will utilize 

both the reports from CCVC and Budget to ensure reported information is accurate and has 

begun to do so at the time of the submission of this letter. 

Recommendation #4: OJP will remedy the $27,929 in unsupported expenditures. 

Response #4: We agree and will work with OJP to remedy the $27,929 in unsupported 

expenditures. 

Recommendation #5: OJP will ensure VCAD implement and adhere to written policies and 

procedures for processing administrative expenses that would prevent such unallowable expenses 

charged to the_grant. 

20 
#5: We agree with this recommendation and VCAD, working with our Budget 

Division, will develop and implement a written policy and procedure for the processing of 

administrative expenses within the OJP Financial Guide to ensure preapproval of administrative 

expenses by the VCAD management team. 

While a written policy is under development, we would like to point out that this work is already 

undetway. For example, it was brought to VCAD 's attention that an unallowable cost was 

charged to the Program's administrative account. After the unallowable expense was identified 

in the audit process, VCAD worked immediately to rectify the issue with our Budget team. 

Recommendation #6: OJP will develop guidance for all State Administering Agencies infom1ing 

them of any requirements regarding crowdfunding funds. 

Response #6: We support this recommendation and encourage the work of OJP, NACVCB and 

other State Administering Agencies to implement any requirements regarding crowdfunding 

funds for eligible claims. Upon receipt of the guidance issued by OJP, the VCAD will assess 

these requfrements in relation to our governing statute and regulations. 

Thank you for the opportunity to provide comments in response to your draft report. We look 

forward to working with you and your team on the implementing the recommendation in the 

weeks ahead. 

Sincerely, 

Ann Meola 

Director 

Victim Compensation & Assistance Division 

21 
 

APPENDIX 4 

OFFICE OF JUSTICE PROGRAMS RESPONSE TO THE 

DRAFT REPORT 

22 

U .S. Department of Justice 

Office of Justice Programs 

Office of Audit, Assessment, and Management 

Washington, D .C. 20531 

uly 16, 2020 

MEMORANDUM TO: Thomas 0. Puerzer 

Regional Audit Manager 

Philadelphia Regional Audit Office 

Office of the Inspector General 

FROM: Ralph E. Martfl_r,_p'LJ..H'. . 

Director , ~,~ ~ 

SUBJECT: Response to the Draft Audit Report, Audit of the Office of 

Justice Programs, Victim Compensa tion Grants Awarded 

to the Massachusetts Department of A ttorney General, 

Boston, Massachusetts 

This mem orandum is in reference to your correspondence, dated June 9, 2020, transmitting the 

above-referenced draft audit report for the Massachusetts Department of Attorney General 

(DAG), Victim Compensatio n Assistance Division (VCAD). W e consider the subject report 

resolved and requ est written acceptance of this action from your office. 

The draft report contains six recommendation s and $27,929 in questioned costs. The followin g 

is the Office of Justice Programs' (OJP) analysis of the draft audit rep ort recommendations. For 

ease of review, the recommendations are r estated in bold and are followed by our response. 

1. We recommend tha t OJP work w ith VCAD to reevaluate their established process 

for claim processing to ensure timely reimburse ment to victims o f crim e. 

OJP agrees w ith this recommendation. We will coordinate with VCAD to reevalu ate its 

estab lished pr ocess for claim processing, to ensure the timely reimbursement to victim s 

of crime. 

2. \Ve recommend tha t OJP ensure VCAD implements and adh eres to comprehensive 

w ritten policies and procedures to ensure its annual state certification form s are 

a ccurate, and supporting documentation is maintained to facilitate review and audit 

o f funds awarded. 

OJP agrees w ith this recommendatio n. We will coordinate with VCAD to obtain a copy 

of w ritten policies and procedures, developed and implem ented, to ensure that its annual 

Crime Victim Compensation (CVC) State Certification Forms are accurate, and that 

supporting documentation is maintained to facilitate rev iew and audit of funds awarded . 
2 

3 . We recommend that OJP ensure VCAD reviews and accurately reports all 

performance data so that OVC can properly monitor how VOCA funds are handled 

and spent. 

OJP agrees with this recommendation. We will coordinate with VCAD to obtain a copy 

of written policies and procedures, developed and implemented, to ensure that it reviews 

and accurately reports all perfom1ance data, so that its Victims of Crime Act (VOCA) 

funds can be properly monitored by the Office for Victims of crime (OVC). 

4. We recommend that OJP remedy the $27,929 in unsupported expenditures. 

OJP agrees with this recommendation. We will review the $27,929 in questioned costs, 

related to unsupported claim expenditures under Award Numbers 2016-VC-GX-0020 and 

201 7-VC-GX-0060, and will work with VCAD to remedy, as appropriate. 

5. We recommend that OJP ensure VCAD implement and adhere to written policies 

and procedures for administrative expenses that would prevent such unallowable 

expenses charged to the grant. 

OJP agrees with this recommendation. We will coordinate with VCAD to obtain a copy 

of written policies and procedures, developed and implemented, to ensure that its 

processes prevent unallowable administrative expenses from being charged to its Federal 

grants. 

6. \Ve recommend that OJP inform SAAs of the applicable VOCA Compensation 

Program requirements regarding crowdfunding and develop appropriate resources 

to assist SAAs in addressing how crowdfunding affects victim compensation. 

OJP agrees with this recommendation. OVC will discuss crowdfunding at a future 

advisory committee meeting, and obtain input from State Administering Agencies 

(SAAs) as to whether/how they have addressed crowdfunding in the compensation 

context. OVC will use the information it receives to produce a communication 

addressing the following: (1) VOCA and the Compensation regulations do not 

specifically address crowdfunding; (2) state law/rules may create requirements with 

regard to crowdfunding; and (3) identification of promising approaches that states use to 

address crowdfunding. 

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

questions or require additional infonnation, please contact Jeffery A. Haley, Deputy Director, 

Audit and Review Division, on (202) 616-2936. 

cc: Katharine T. Sullivan 

Principal Deputy Assistant Attorney General 

23 
3 

cc : Maureen A. Henneberg 

Deputy Assistant Attorney General 

for Operations and Management 

LeToya A. Johnson 

Senior Advisor 

Office of the Assistant Attorney General 

Jeffery A. Haley 

Deputy Director, Audit and Review Division 

Office of Audit, Assessment, and Management 

Jessica E. Hart 

Director 

Office for Victims of Crime 

Bill Woolf 

Senior Advisor 

Office for Victims of Crime 

Katherine Darke-Schmitt 

Deputy Director 

Office for Victims of Crime 

Kathrina S. Peterson 

Acting Deputy Director 

Office for Victims of Crime 

James Simonson 

Associate Director for Operations 

Office for Victims of Crime 

Deserea Jackson 

Grants Management Specialist 

Office for Victims of Crime 

Leigh A. Benda 

Chief Financial Officer 

Christal McNeil-Wright 

Associate Chief Financial Officer 

Grants Financial Management Division 

Office of the Chief Financial Officer 

24 
4 

cc : Joanne M. Suttington 

Associate Chief Financial Officer 

Finance, Accounting, and Analysis Division 

Office of the Chief Financial Officer 

Aida Brummc 

Manager, Evaluation and Oversight Branch 

Grants Financial Management Division 

Office of the Chief Financial Officer 

Louise Duhamel 

Acting Assistant Director, Audit Liaison Group 

Internal Review and Evaluation Office 

Justice Management Division 

OJP Executive Secretariat 

Control Number IT20200609 150740 

25 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

APPENDIX 5 

OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY 

OF ACTIONS NECESSARY TO CLOSE THE REPORT 

The OIG provided a draft of this audit report to the Office of Justice Programs 

(OJP) and the Massachusetts Department of Attorney General, Victim Compensation 

and Assistance Division (VCAD). VCAD’s response is incorporated in Appendix 3 

and OJP’s response in Appendix 4 of this final report. VCAD either agreed with or 

supported all our recommendations. In its response, OJP agreed with all our 

recommendations and discussed the actions it plans to complete to address our 

recommendations. As a result, the status of the audit report is resolved. The 

following provides the OIG analysis of the response and a summary of the actions 

necessary to close the report. 

Recommendations for OJP: 

1. Work with VCAD to reevaluate their established process for claim 

processing to ensure timely reimbursement to victims of crime. 

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

that it will coordinate with VCAD to reevaluate its established process for 

claim processing to ensure the timely reimbursement to victims of crime. 

VCAD agreed with this recommendation. In its response, VCAD stated that it 

will assess each stage of its review process to ensure the timely processing of 

claims and reimbursements. This will include more specific timeframes for 

eligibility decision-making in claims where limited law enforcement 

information is available. VCAD further said that updates to its processes will 

be reviewed by the Attorney General’s Office Executive Bureau and discussed 

with OJP. 

This recommendation can be closed when we receive documentation 

demonstrating VCAD has reviewed and updated its claim reimbursement 

processes to address timeliness of claims processing. 

2. Ensure VCAD implements and adheres to comprehensive written 

policies and procedures to ensure its annual state certification forms 

are accurate, and supporting documentation is maintained to 

facilitate review and audit of funds awarded. 

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

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

procedures, developed and implemented, to ensure that its annual state 

certification forms are accurate, and that supporting documentation is 

maintained to facilitate review and audit of funds awarded. 

VCAD agreed with this recommendation. In its response, VCAD stated that it 

will work with their Budget Division to ensure that all data submitted is 

26 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

reviewed and reconciled prior to the submission of the annual state 

certification form. 

This recommendation can be closed when we receive documentation 

demonstrating VCAD has implemented comprehensive written policies and 

procedures to ensure its annual state certification forms are accurate and 

supporting documentation is maintained to facilitate review and audit of funds 

awarded. 

3. Ensure VCAD reviews and accurately reports all performance data so 

that OVC can properly monitor how VOCA funds are handled and 

spent. 

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

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

procedures, developed and implemented, to ensure that it reviews and 

accurately reports all performance data, so that its Victims of Crime Act 

(VOCA) funds can be properly monitored by the Office for Victims of Crime 

(OVC). 

VCAD agreed with this recommendation. In its response, VCAD stated that it 

will develop an internal policy of how data is collected and maintained for the 

quarterly PMT reports. Specifically, VCAD will utilize both the reports 

generated from its case management system and budget to ensure reported 

information is accurate. VCAD further said it began this effort at the time of 

its response to our report. 

This recommendation can be closed when we receive documentation 

demonstrating VCAD has developed and implemented an internal policy on 

how data is collected and maintained for the quarterly PMT reports. 

4. Remedy the $27,929 in unsupported expenditures. 

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

that it will review the $27,929 in questioned costs, related to unsupported 

claim expenditures under Award Numbers 2016-VC-GX-0020 and 

2017-VC-GX-0060, and will work with VCAD to remedy the expenditures as 

appropriate. 

VCAD agreed with this recommendation and stated it will work with OJP to 

remedy the unsupported expenditures. 

This recommendation can be closed when we receive documentation 

demonstrating that OJP has coordinated with VCAD to remedy the $27,929 in 

unsupported claim expenditures. 

27 
 

 

 

 

 

 

 

 

 

 

 

5. Ensure VCAD implement and adhere to written policies and 

procedures for processing administrative expenses that would 

prevent such unallowable expenses charged to the grant. 

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

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

procedures, developed and implemented, to ensure that its processes prevent 

unallowable administrative expenses from being charged to its federal grants. 

VCAD agreed with this recommendation. In its response, VCAD stated that it 

is currently working with their Budget Division to develop and implement a 

written policy and procedure for the processing of administrative expenses in 

conformity with the OJP Financial Guide to ensure preapproval of 

administrative expenses by the VCAD management team. 

This recommendation can be closed when we receive documentation 

demonstrating VCAD has developed and implemented a written policy and 

procedure for the processing of administrative expenses. 

6. Inform all SAAs nationwide of the applicable VOCA Compensation 

Program requirements regarding crowdfunding and develop 

appropriate resources to assist SAAs in addressing how 

crowdfunding affects victim compensation. 

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

that it will discuss crowdfunding at a future advisory committee meeting and 

obtain input from State Administering Agencies (SAAs) as to whether/how 

they have addressed crowdfunding in the victim compensation context. OVC 

further stated it will use the information to produce a communication 

addressing the following: (1) VOCA and the Victim Compensation regulations 

do not specifically address crowdfunding; (2) state law/rules may create 

requirements with regard to crowdfunding; and (3) identification of promising 

approaches that SAAs use to address crowdfunding. 

VCAD supported this recommendation. In its response, VCAD stated that 

upon receipt of the guidance issued by OJP, VCAD will assess these 

requirements in relation to its governing statute and regulations. 

This recommendation can be closed when we receive documentation 

demonstrating OVC has produced a communication that addresses 

crowdfunding issues and identifies positive approaches all SAAs nationwide 

can use to address crowdfunding. 

28