Office of the Inspector General 

U.S. Department of Justice 

Audit of the Office on Violence 

Against Women Grant 

Awarded to 

Shelter from the Storm, 

Incorporated 

Island City, Oregon
 

Audit Division GR-90-17-001 January 2017 

REDACTED – FOR PUBLIC RELEASE 
 

 

 

 

AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN GRANT 

AWARDED TO SHELTER FROM THE STORM, INCORPORATED 

ISLAND CITY, OREGON
 

EXECUTIVE SUMMARY
 

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

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

Women (OVW) to Shelter From the Storm, Incorporated (SFS) located in 

Island City, Oregon. The SFS was awarded $747,262 under grant number 

2013-WR-AX-0030 to: (1) have designated personnel working to increase victim 

safety and hold abusers accountable for their crimes; (2) provide support to assist 

victims’ healing and recovery following an incident of sexual assault, domestic 

violence, dating violence, and stalking; (3) enhance the ability of rural victims to 

access advocacy services and resources; and (4) allow victims to access 

professionals trained specifically in areas of sexual assault, domestic violence, 

dating violence, and stalking. As of July 7, 2016, the SFS had expended $660,921 

(88 percent) of the total grant funds awarded. 

The objective of this audit was 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 this 

objective, we assessed performance in the following areas of grant management: 

financial management, Federal Financial Reports (FFR), budget management and 

control, drawdowns, expenditures, and program performance. 

As a result of our audit, we found that the SFS did not comply with essential 

award requirements in four of the six areas we tested and generally complied with 

requirements related to program performance and budget management. We noted 

weaknesses in the internal control environment, grant expenditures, contractor 

oversight, and reporting, including non-compliance with award requirements. 

Specifically, the SFS could not adequately support $284,785 in expenditures for 

contractual services provided by a dedicated counselor, law enforcement detective, 

and county probation officer. The SFS also paid $18,107 in unallowable contractual 

services for the counseling sessions, which included: (1) $4,511 in probation 

officer contractor costs above the agreed upon cost of 50 percent; (2) $7,076 in 

counselor contractor costs above the agreed upon hourly rate of $29 per hour; and 

(3) $6,520 in counselor contractor costs for charges when victims did not show up 

or cancelled their appointments. We found $24,149 in salary and associated fringe 

benefit expenditures that were not adequately supported by timesheets showing 

the amount of time worked on grant-related activities. Furthermore, the SFS 

grant-related expenditures included $21,311 for personnel that had not been 

approved in the budget. In addition, we questioned $2,549 in inadequately 



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

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

i 
 

 

 

 

supported non-personnel direct costs related to insurance, travel and training, 

office supplies, and printing expenses. We also questioned $1,085 in employer 

funded health insurance premiums that were inadequately supported with receipts, 

invoices, and other documents. Although the SFS was making progress in 

achieving its grant goals and objectives, the SFS did not accurately report the 

number of victim served on its Progress Reports. The SFS failed to submit accurate 

Progress Reports for three semiannual periods. Finally, we found that the SFS drew 

down advances on six occasions and did not use those funds within 10 days as 

required by the grant. Lastly, eight FFRs that we tested were inaccurate. 

These items are discussed in detail in the report. Our report questions a 

total of $351,986 and contains 11 recommendations to OVW. We discussed the 

results of our audit with SFS officials and have included their comments in the 

report, as applicable. Our audit objective, scope, and methodology are discussed in 

Appendix 1. Our Schedule of Dollar-Related Findings is located in Appendix 2. In 

addition, we requested written responses from SFS and OVW to the draft copy of 

our audit report. We received those responses and they are found in Appendices 3 

and 4, respectively. Our analysis of those responses and the summary of actions 

necessary to close the recommendations are found in Appendix 5. 

ii 
AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN GRANT 

AWARDED TO SHELTER FROM THE STORM, INCORPORATED 

ISLAND CITY, OREGON
 

TABLE OF CONTENTS
 

Shelter from the Storm .................................................................................. 1
 

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

Program Performance and Accomplishments ..................................................... 2
 

Program Goals and Objectives ............................................................... 2
 

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

Compliance with Special Conditions ........................................................ 4
 

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

Single Audit ........................................................................................ 5
 

Financial Management System ............................................................... 6
 

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

Non-Personnel Costs ............................................................................ 6
 

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

Monitoring of Sub-Recipients and Contractors .......................................... 8
 

Detective and Probation Officers ............................................................ 9
 

Contracted Counselor ........................................................................... 9
 

Budget Management ................................................................................... 10
 

Drawdowns ................................................................................................ 10
 

Federal Financial Reports ............................................................................. 12
 

Conclusion................................................................................................. 13
 

Recommendations ...................................................................................... 13
 

APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY .................................. 15
 

APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS ............................... 17 
APPENDIX 3: SHELTER FROM THE STORM RESPONSE TO THE DRAFT AUDIT 

REPORT.......................................................................................................... 18 

APPENDIX 4: OFFICE ON VIOLENCE AGAINST WOMEN RESPONSE TO THE DRAFT 

AUDIT REPORT............................................................................................ 22 

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

ACTIONS NECESSARY TO CLOSE THE REPORT................................... 25 
 

 

 

AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN GRANT 

AWARDED TO SHELTER FROM THE STORM, INCORPORATED 

ISLAND CITY, OREGON
 

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

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

Women (OVW) under the Rural Domestic Violence, Dating Violence, Sexual Assault, 

and Stalking Assistance Program to Shelter From the Storm, Incorporated (SFS) 

located in Island City, Oregon. Specifically, the SFS was awarded grant 

2013-WR-AX-0030 totaling $747,262, as shown in Table 1. As of July 7, 2016, the 

SFS had expended $660,921 (88 percent) of the total grant funds awarded. 

Table 1 

OVW Grant Awarded to Shelter from the Storm
 

Grant Award Number Award Date 

Award 

Start Date 

Award 

End Datea Award Amount 

2013-WR-AX-0030 09/19/13 10/01/13 12/31/16 $ 747,262 

a

 The Award End Date includes all time extensions that were approved by OVW. 

Source: OVW 

Funding through the Rural Domestic Violence, Dating Violence, Sexual 

Assault, and Stalking Assistance Program supports enhanced victim safety in cases 

of sexual assault, domestic violence, dating violence, and stalking in rural areas and 

rural communities by encouraging collaborative partnerships among criminal justice 

agencies, victim service providers, and community organizations to respond to 

these crimes. In addition, the program supports the provision of services to the 

victims of such violence, and encourages communities to work in coordination to 

develop education and prevention strategies directed toward these issues. 

Shelter from the Storm 

Located 172 miles northwest of Boise, Idaho, the SFS is a 501(c) not-forprofit corporation started in 1979 as a domestic violence and sexual assault crisis 

center located in Island City, Oregon. The SFS’s mission is to break the cycle of 

domestic and sexual abuse in their community through intervention, individual 

advocacy, and awareness. To accomplish its mission, it offers services such as a 

24-hour crisis hotline, a 14-bed emergency shelter, a transitional housing program, 

transportation, counseling, and more. 

OIG Audit Approach 

The objective of this audit was 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 this 

1
 
 

 

 

 

objective, we assessed performance in the following areas of grant management: 

financial management, Federal Financial Reports (FFR), budget management and 

control, drawdowns, expenditures, and program performance. 

We tested the SFS’s compliance with what we consider to be the most 

important conditions of the grant award. Unless otherwise stated in our report, the 

criteria we audited against are contained in the OVW Financial Grants Management 

Guide, Code of Federal Regulations, Office of Management and Budget Circulars, 

and the grant award documents. 

The results of our audit are discussed in detail below. We discussed the 

results of our audit with SFS officials and have included their comments in the 

report, as applicable. Our report contains 11 recommendations to OVW. 

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

methodology. Our Schedule of Dollar-Related Findings is located in Appendix 2. In 

addition, we requested written responses from SFS and OVW to the draft copy of 

our audit report. We received those responses and they are found in Appendices 3 

and 4, respectively. Our analysis of those responses and the summary of actions 

necessary to close the recommendations are found in Appendix 5. 

Program Performance and Accomplishments 

In order to determine whether the SFS demonstrated adequate progress 

towards achieving its grant program goals and objectives, we: (1) reviewed 

required performance reports, grant solicitation, and grant documentation; 

(2) interviewed SFS officials; and (3) analyzed supporting documentation. In 

addition, we reviewed the accuracy of the Progress Reports that the SFS submitted 

to OVW. Finally, we reviewed the SFS’s compliance with the special conditions 

identified in the grant award documentation. 

Program Goals and Objectives 

According to OVW’s grant solicitation, the primary purpose of the grant was 

to identify, assess, and respond to victims of sexual assault, domestic violence, 

dating violence, and stalking in rural areas by encouraging collaboration among 

victim service providers (law enforcement agencies, prosecutors, courts, other 

criminal justice service entities, and health care entities), who provide services for 

victims of sexual assault, domestic violence, dating violence, and stalking. To 

achieve this purpose, the SFS included in its grant application the following specific 

grant goals and objectives: (1) have designated personnel working to increase 

victim safety and hold abusers accountable for their crimes; (2) provide support to 

assist victims’ healing and recovery following an incident of sexual assault, 

domestic violence and stalking; (3) enhance the ability of rural victims to access 

advocacy services and resources; and (4) allow victims to access professionals 

trained specifically in areas of sexual assault, domestic violence, dating violence 

and stalking. 

2
 
 

 

 

 

We reviewed relevant documentation to determine if the SFS was on track to 

meeting all four goals and objectives. For its first goal, we found that the SFS 

designated personnel to work on increasing the safety of victims and hold abusers 

accountable for their crimes. Specifically, the SFS entered into an agreement with 

the La Grande Police Department (LGPD) and County of Union Probation 

Office (CUPO). The LGPD agreed to provide one full-time detective who was 

designated to spend all of his time working on domestic violence cases, serving 

restraining orders, and responding to domestic violence calls among other duties. 

In addition, the CUPO agreed to provide a part-time probation officer to meet with 

domestic violence abusers who were on probation. We interviewed the Detective 

and the Probation Officer as well as observed the patrol car that was purchased 

with grant funds for the Detective’s use. Overall, the SFS made progress in 

accomplishing the first grant goal. 

For its second goal, we found that the SFS provided counseling sessions, 

advocacy services, crisis intervention, emotional support, safety planning, and 

referrals to victims of sexual assault, domestic violence, and stalking. To meet its 

third goal of enhancing the ability of rural victims to access advocacy services and 

resources, the SFS purchased a van and utilized it to provide transportation for 

victims. The SFS’s more specific goal was to provide transportation services for 

victims in at least 300 instances. As of April 2016, the SFS had provided 

transportation services to victims in at least 122 instances. It appeared to us 

during our fieldwork that the SFS was making an effort toward achieving its third 

goal. 

For the final goal of allowing victims to access specially trained professionals, 

as of April 2016, the SFS completed a total of 1,059 counseling sessions. The SFS’s 

more specific goal was to complete 1,800 counseling sessions. It appeared to us 

during our fieldwork that the SFS was making progress toward achieving this 

particular goal. 

Required Performance Reports 

According to the OVW Financial Grants Management Guide, the SFS was 

required to ensure that valid and auditable source documentation was maintained 

and made available to support all data collected for each performance measure 

specified in the program solicitation. In order to test the accuracy of the 

performance measurement information in the SFS’s Progress Reports, we 

judgmentally selected one performance measure (the number of clients served) 

from the three judgmentally selected Progress Reports, which we believe was the 

most important statistic. We then traced this reported statistic to supporting 

documentation maintained by the SFS. 

We found that the Progress Reports for periods ending December 31, 2014, 

June 30, 2015, and December 31, 2015, did not accurately reflect the number of 

clients (victims) served by the SFS. The SFS’s process for gathering this 

performance metric began with each victim completing an intake form. Information 

3
 
 

 

 

provided on those forms was then entered into a database called Alice that was 

specifically designed to support the SFS’s reporting needs. The statistics included 

on each Progress Report were obtained from both the data in Alice and from 

statistical information provided by the grant-funded Union County probation officer, 

who reported the number of victims he referred to the SFS. The SFS provided to us 

statistical data from Alice for each reporting period along with intake forms to 

support some of the entries made in Alice. However, the SFS was unable to 

provide supporting documentation (intake forms) for two of the three reporting 

periods (ending December 31, 2014, and June 30, 2015) we tested because of its 

document-retention practices, in which it shredded all intake forms after 3 months. 

The practice of destroying underlying support for grant reports is contrary to grant 

rules that require all grant documentation be maintained for a minimum of 3 years 

after the submission of the final expenditure report. We compared the statistics 

included in the Alice report for each of the three reporting periods against the 

statistics included in the Progress Reports that the SFS submitted into the Office of 

Justice Programs’ (OJP) Grant Management System (GMS). As shown in Table 2, 

we found three performance measurement values that were overstated and thereby 

inaccurate. 

Table 2 

Accuracy of the SFS’s Progress Reports 

OVW Grant 2013-WR-AX-0030
 

Progress Report 

Period Ending Date 

Number of Clients 

Served According to 

Alice Report 

Number of Clients 

Served Reported on 

Progress Report Difference 

12/31/14 53 55 2 

06/30/15 71 79 8 

12/31/15 78 101 23

 Source: OIG analysis of OVW data and the SFS’s records 

In our review of the Progress Report for the period ending December 31, 

2015, we examined supporting documentation for the corresponding data in Alice 

and determined that the SFS’s Executive Director had counted victims more than 

once or included secondary victims in her count. In doing so, she made an error in 

counting the number of clients served. For the two earlier Progress Reports, we 

were only able to compare the data in Alice to the numeric information included in 

the Progress Reports because as mentioned above, the SFS failed to maintain 

supporting documents such as intake forms. We recommend that OVW ensure that 

the SFS prepares and submits accurate Progress Reports and maintains sufficient 

documentation to support grant-related accomplishments. 

Compliance with Special Conditions 

Special conditions are contractual terms and conditions that are included with 

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

judgmental sample of two requirements (Special Condition numbers 22 and 25) 

4
 
 

that were significant to grant performance and that were not addressed in another 

section of this report. 

Special Condition number 22 required the SFS to collect and maintain data 

that measured the effectiveness of its grant-funded activities. This requirement 

included that the SFS maintain intake forms that supported the metric on the 

number of victims that the SFS served. As we previously discussed in the Required 

Performance Reports section of this report, the SFS failed to maintain all of the 

intake forms that victims prepared upon receiving service or assistance from the 

SFS. Instead, the SFS destroyed through shredding all intake forms after 

3 months. Therefore, the SFS failed to comply with Special Condition number 22. 

As a result, we recommend that OVW ensure that the SFS establishes a process to 

maintain all supporting documentation, including intake forms, for data that 

measures the effectiveness of its grant-funded activities. 

Special Condition number 25 required the SFS to attend and participate in 

OVW-sponsored technical assistance, which may include, but is not limited to, 

national and regional conferences, audio conferences, webinars, peer-to-peer 

consultations, and workshops conducted by OVW-designated technical assistance 

providers. We found that SFS employees attended and participated in OVWsponsored technical assistance. Therefore, the SFS complied with Special Condition 

number 25. 

Grant Financial Management 

According to the OVW Grants Financial Management Guide, all grant 

recipients are required to establish and maintain adequate accounting systems and 

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

the SFS’s financial management of the grant covered by this audit, we reviewed the 

SFS’s policies and procedures and financial management system to assess its risk 

of noncompliance with laws, regulations, guidelines, and terms and conditions of 

the grant. We also interviewed the SFS’s Executive Director regarding internal 

controls and processes related to payroll, purchasing, and accounts payable 

functions. Finally, we performed testing in the areas that were relevant for the 

financial management of this grant. 

Single Audit 

According to Office of Management and Budget Circular A-133, non-federal 

entities that expend $500,000 or more in federal awards in a year shall have a 

Single Audit conducted. We reviewed the SFS’s accounting records and determined 

that it did not expend $500,000 or more in federal awards. Therefore, a Single 

Audit was not required and according to the SFS’s Executive Director, the SFS has 

not had a Single Audit performed. 

5
 
 

 

 

 

 

Financial Management System 

The OVW Financial Grants Management Guide requires that all grant fund 

recipients “. . . establish and maintain accounting systems and financial records to 

accurately account for funds awarded to them.” This requirement includes 

maintaining adequate financial data to record and report on the receipt, obligation, 

and expenditure of grant funds. Furthermore, the guide stipulates that grantees 

must account for each award separately and may not commingle grant funds. 

During the grant period, the SFS utilized an accounting system called Sage 

Works before transitioning to QuickBooks. The SFS’s former Fiscal Manager 

performed the SFS’s bookkeeping until her resignation in February 2015. 

Afterwards, the SFS contracted with a local CPA firm for bookkeeping services and 

to convert the SFS’s accounting records to QuickBooks. Based on our review of 

grant-related transactions that were recorded in both Sage Works and QuickBooks, 

we generally found that the systems accurately accounted for grant-related receipts 

and expenditures. Further, we found that grant-related transactions (i.e., receipts 

and expenditures) were separately tracked from all other funding. However, as we 

discuss in the Grant Expenditures section of this report, we found instances where 

the SFS failed to maintain adequate support for expenditures and lacked written 

policies and procedures. We regard these findings as internal control weaknesses. 

Grant Expenditures 

As of July 7, 2016, the SFS had expended $660,921 (88 percent) of the total 

grant award. The expenditures were comprised of personnel, contractor, travel, 

training, equipment, supplies, and other costs. We judgmentally selected a sample 

of 41 non-personnel transactions totaling $70,533 in order to determine if costs 

charged to the grant were allowable, properly authorized, adequately supported, 

and in compliance with grant terms and conditions. The expenditures we selected 

included equipment, travel, supplies, and other expenditures. We reviewed 

supporting documentation including invoices, receipts, and check copies. 

Additionally, for our personnel testing, we judgmentally selected two nonconsecutive payroll periods in order to test salary and fringe benefits expenses. For 

these expenditures, we reviewed payroll reports, timesheets, and other supporting 

documentation. We discuss below each of these tests and our results. 

Non-Personnel Costs 

As mentioned above, we judgmentally selected 41 non-personnel 

transactions and reviewed these expenditures to determine if costs charged to the 

grants were accurate, adequately supported, allowable, reasonable, and allocable. 

According to the OVW Financial Grants Management Guide, “to be allowable under 

the Federal awards, costs must . . . be adequately documented.” Of our sample, 31 

transactions were adequately supported, allowable, reasonable, and allocable. The 

remaining 9 transactions totaling $2,549 related to insurance, travel and training, 

office supplies, and printing that were inadequately supported due to missing 

6
 
 

 

 

 

 

receipts, unsupported methodology for the allocation of expenditures to the grant, 

or used for unknown purposes. Additionally, we found a $110 transaction related 

to medical expense that was misallocated to the wrong grant. Given the low-dollar 

threshold of this misallocation, we did not question the $110. As a result, we 

questioned the $2,549 in inadequately supported non-personnel expenditures and 

recommend that OVW remedy this amount.1 

Personnel Costs 

We tested the grant-related personnel expenditures to determine if these 

expenditures were allowable, reasonable, and adequately supported. Specifically, 

we selected a judgmental sample of two non-consecutive pay periods from each 

accounting system, which included salary and fringe benefit expenditures for the 

months of July 2014, January 2015, August 2015, and October 2015. In total, we 

tested $21,825 in salary expenses for those months and $5,220 in fringe benefit 

expenditures for those months plus September 2015. As part of our personnel 

expenditure testing, we reviewed supporting documentation, such as time and 

attendance records, to determine whether the: (1) positions paid with grant funds 

appeared reasonable with the stated intent of the program, (2) salaries of the 

employees paid with grant funds were within a reasonable range, and (3) salary 

and fringe benefit expenditures were adequately supported. 

We obtained a list of employees paid using grant funds and compared this list 

with the positions included in the OVW-approved grant budget. The SFS funded a 

total of five positions with grant funds, of which two were included in the approved 

budget and one was subsequently approved by OVW after the grant began. The 

remaining two positions, Executive Director and Advocate, were not approved by 

OVW when we conducted our fieldwork. As a result, we questioned $21,311 in 

salary and associated fringe benefits for both of the unapproved grant-funded 

positions. 

We compared the salaries paid for the three grant-funded positions approved 

by OVW with salaries paid in the area near the SFS for similar positions. We found 

that the salaries that the SFS paid were reasonable. 

According to 2 C.F.R. § 230, “[t]he reports must reflect an after-the-fact 

determination of the actual activity of each employee. Budget estimates (i.e., 

estimates determined before the services are performed) do not qualify as support 

for charges to awards. . . The reports must be prepared at least monthly and must 

coincide with one or more pay periods.” In our review of the SFS’s timesheets and 

payroll records, we found that the timesheets and records did not break down work 

performed by project. The timesheets recorded the time in, time out, and total 

1

 The Inspector General Act of 1978, as amended, contains our reporting requirements for 

questioned costs. However, not all findings are dollar-related. See Appendix 2 for a breakdown of our 

dollar-related findings and the definitions of questioned costs. 

7
 
 

 

 

 

 

hours worked for each employee; however, the timesheets did not separate time 

worked on each project. Without a breakdown by project, the SFS lacked adequate 

support that could allow us to verify that the amount spent on personnel costs were 

in fact grant-related. Therefore, we questioned $24,149 in inadequately supported 

personnel costs for the five positions that were paid from the grant. 

In addition, in our review of fringe benefits, the SFS could not provide us 

with support (receipts, invoices, and other documents) for some of the health 

insurance premiums and as such, we could not determine if those fringe benefits 

were reasonable, computed correctly, or properly charged to the grant. Thus, we 

questioned a total of $1,085 in fringe benefit costs that were inadequately 

supported. 

As a result of our personnel cost testing, we questioned a total of $21,311 in 

unallowable personnel costs and a total of $25,234 in inadequately supported 

personnel costs as described above. We also made recommendations to OVW to 

remedy these questioned costs. 

Monitoring of Sub-Recipients and Contractors 

The SFS entered into an agreement with: (1) the LGPD to provide a full-time 

detective for dedicated policing services in domestic violence cases, (2) the County 

of Union Probation Office (CUPO) to provide a part-time probation officer to follow 

up on sex offenders, and (3) a counselor to provide counseling to victims. In 

December 2014, the contract counselor terminated her agreement and involvement 

with the SFS and instead the SFS, with OVW’s approval, hired a counselor to 

provide counseling services. 

The SFS did not have written policy or procedures for monitoring contractors 

or for procuring contractual services. Based on what we were able to determine, 

the former Executive Director selected the contractors for the grant and awarded 

the contracts. The SFS’s current Executive Director did not have any information 

on the process that was utilized by the former Executive Director to select the 

contractors mentioned above or to award the grant-related contracts. We reviewed 

the Memorandum of Understanding that the SFS entered into with the LGPD and 

CUPO and we did not take issue with the selection of these organizations as 

contractors because these entities provided a unique service and were the only 

providers of those services in La Grande, Oregon. However, we take exception with 

the SFS’s failure to maintain documentation on how it selected and awarded the 

contract to the counselor because without that type of documentation, it was 

unclear whether the contract counselor was properly selected. The OVW Financial 

Grants Management Guide stated, “direct recipients should ensure that monitoring 

of organizations under contract to them is performed in a manner that will ensure 

compliance with their overall financial management requirements.” We recommend 

OVW ensure that the SFS creates written policies or procedures for proper 

contractor oversight as well as procurement and that it maintain all contract related 

documentation. 

8
 
 

 

 

Detective and Probation Officers 

The SFS used grant funds to fund a full-time detective at the LGPD to 

respond, investigate, and follow up on all sexual assault, domestic violence, dating 

violence, and stalking incidences that are reported to the LGPD. In addition, the 

SFS used grant funds to pay for a part-time CUPO probation officer to monitor and 

ensure abusers are meeting court ordered sentencing requirements, as well as 

immediate sanctions for non-compliance with any sentencing provisions. 

In our judgmental sample, we reviewed 16 transactions (8 LGPD and 8 CUPO 

invoices), totaling $284,785, that were related to the Detective’s and Probation 

Officer’s agreed to services. We found that the SFS paid these invoices without 

requiring support for the hours worked. Without supporting documentation 

(timesheets, semi-annual certifications, etc.), the SFS was unable to confirm and 

document how much time the Detective spent on grant-related activity. In an 

interview with the Detective, he stated that besides working on domestic violence 

cases, he also worked on criminal cases that were not related to domestic violence. 

Likewise, the SFS did not have timesheets to support the Probation Officer’s 

invoices to ensure that he spent at least 50 percent of his time on grant-related 

activity. We found that the SFS paid more than 50 percent of the Probation 

Officer’s salary on five occasions; the overage totaled $4,511. We asked the SFS’s 

Executive Director why the SFS paid both LGPD and CUPO invoices without 

reviewing the Detective’s and Probation Officer’s timesheets. The SFS Executive 

Director stated she continued the same process established by the previous 

Executive Director and Fiscal Manager, which did not include the review or 

maintenance of timesheets for LGPD and CUPO personnel. Based on our findings, 

we questioned all of the LGPD and CUPO transactions, totaling $284,785, as 

inadequately supported costs and $4,511 in overpayments to the CUPO as 

unallowable. 

Contracted Counselor 

The SFS also utilized grant funds to pay a dedicated counselor for victim 

services. We reviewed 13 transactions, totaling $31,750, related to the contract 

counselor. According to the contract, the SFS agreed to pay the counselor $29 per 

hour for counseling services. However, we found that the SFS paid the contractor 

more than 800 times at $40 per hour ($11 more than the agreed upon rate) for a 

total overage of $7,076. We asked if there were any amendments to the contract 

between the SFS and the counselor. The SFS did not have any amendments to the 

contract to approve the increase in rate to $40 per hour. We asked the SFS 

Executive Director why the contract counselor was paid more than the stated 

contract rate of $29. The SFS Executive Director stated the approved budget 

included a counselor for 1,800 sessions at a billable rate of $40 per hour. Even 

though the approved budget allowed $40 per hour, the contract that the SFS 

awarded and that the counselor agreed to was for $29 per hour. Therefore, we 

questioned $7,076 in counselor payments as unallowable payment more than what 

was allowed under the counselor contract. 

9
 
 

In addition to the SFS overpaying the counselor, the SFS also paid the 

counselor $6,520 for 163 cancelled and no-show counseling sessions. According to 

the contract, the SFS should have paid only for completed work; the contract had 

no provision for the counselor to be paid for no-shows or cancelled sessions. We 

asked the SFS Executive Director why the SFS paid for cancellations and no-shows. 

The SFS Executive Director stated that the former Executive Director and former 

Fiscal Manager handled those payments and she continued with the process that 

was previously established. Because payments for cancellations and no-shows are 

not allowed, we questioned $6,520 in payments to the contract counselor for 

cancelled or no-show sessions. 

Budget Management 

The OVW Financial Grants Management Guide and 28 C.F.R. 70 require prior 

approval from the awarding agency if the movement of dollars between budget 

categories exceeds 10 percent of the total award amount for awards over 

$100,000. Based on our review of the award package and grant solicitation, we 

determined that the grant exceeded the $100,000 threshold and was subject to the 

10 percent rule. Our analysis of the budget as compared to actual expenditures did 

not identify budget deviations that would require OVW approval. 

Drawdowns 

According to the OVW Financial Grants Management Guide, grant recipients 

should request funds based upon immediate disbursement or reimbursement 

needs. Specifically, recipients should time their drawdown requests to ensure that 

federal cash-on-hand is the minimum needed for disbursement or reimbursement 

to be made immediately or within 10 days. The SFS Executive Director stated that 

grant funds were drawn down on a reimbursement basis. 

As of September 2, 2016, the SFS had drawn down a total of $678,020. We 

analyzed all drawdowns from the start of the grant on October 1, 2013, through 

September 2, 2016, by comparing the amounts and dates of the drawdowns to the 

SFS’s accounting records with the additional 10-day grace period. We found that 

the SFS drawdowns exceeded expenditures, as shown in Table 3. 

10
 
 

 

 

 

Table 3 

Analysis of the SFS’s Drawdown History
 

Number of 

Drawdowns 

Drawdown 

Amount 

Expenditures on 

General Ledger Difference Running Total 

1 $99,856 $104,918 $5,062 $5,062 

2 61,825 60,185 <1,640> 3,422 

3 59,249 114,096 54,848 58,269 

4 57,303 7,969 <49,334> 8,935 

5 57,131 47,218 <9,913> <977> 

6 56,274 54,610 <1,663> <2,641> 

7 63,138 48,679 <14,459> <17,099> 

8 54,863 64,388 9,525 <7,575> 

9 63,288 54,460 <8,827> <16,402> 

10 22,262 76,795 54,533 38,131 

11 82,833 43,538 <39,294> <1,163> 

Total $678,022 $676,856 <$1,163> <$1,163> 

Note: The total amounts do not equate to the mathematical totals calculated within the table due 

to rounding. 

Source: OVW and OIG Analysis of the SFS Accounting Records 

Specifically, we found that during a 13-month period, the SFS had drawn 

down an average of $8,939 more than its expenditures from February 13, 2015, to 

March 20, 2016. Specifically, the SFS drew down funds five times resulting in 

advances ranging from as little as $977 to as much as $17,099. By March 21, 

2016, the SFS had exhausted the cash advance for the grant. Additionally, the SFS 

had drawn down $1,163 more than its expenditures on July 7, 2016. By July 29, 

2016, the SFS had used the cash advance for the grant. The SFS did not have 

written drawdown procedures. We asked SFS officials how they determined the 

amounts that they should draw down. The SFS Executive Director stated that 

drawdown amounts were based on the total quarterly expenditures reported on the 

FFRs. As shown below in the FFRs section of this report, the total expenditures 

recorded on the FFRs also did not match the SFS’s total expenditures for the 

quarter. Thus, we found that the SFS did not time its drawdown requests to ensure 

that federal cash on hand is the minimum needed for disbursement to be made 

immediately or within 10 days. We recommend OVW ensure that the SFS creates 

and implements written drawdown procedures to ensure that federal cash on hand 

is the minimum needed for disbursements to be made immediately or within 10 

days. 

11
 
Federal Financial Reports 

According to the OVW Financial Grants Management Guide, award recipients 

are required to submit quarterly FFRs and report program expenditures and 

revenue in accordance with their accounting system. These reports describe the 

status of the funds. According to the OVW Financial Grants Management Guide, the 

FFR should contain the cumulative expenditures and unliquidated obligations 

incurred for the grant as well as program income and indirect costs. The 

expenditures and revenue recorded on an FFR should be on a cash or accrual basis 

in accordance with the award recipient’s accounting system. As shown in Table 4 

below, we reviewed the first eight FFRs submitted by the SFS and found that the 

expenditures included on the SFS’s FFRs did not match the actual expenditures 

recorded in its official accounting records. 

Table 4 

Accuracy of the SFS’s Federal Financial Reports 

OVW GRANT 2013-WR-AX-0030
 

Report 

No. 

Reporting 

Period 

Expenditures 

Reported 

on FFR 

Grant-Related 

Expenditures 

Difference 

Between FFRs and 

Accounting 

Records 

1 10/01/13 - 12/31/13 $99,856 $93,162 $6,694 

2 01/01/14 - 03/31/14 61,825 62,141 <316> 

3 04/01/14 - 06/30/14 57,303 56,890 413 

4 07/01/14 - 09/30/14 59,249 58,660 589 

5 10/01/14 - 12/31/14 57,131 57,294 <163> 

6 01/01/15 - 03/31/15 20,127 9,402 10,724 

7 04/01/15 - 06/30/15 27,700 100,126 <72,426> 

8 07/01/15 - 09/30/15 19,066 80,997 <61,931> 

Total 402,257 $518,672 <$116,416> 

Note: The total amounts do not equate to the mathematical totals calculated within the table 

because of rounding. 

Source: OIG analysis of OVW data and the SFS’s accounting records. 

The SFS was unable to explain what caused the difference between 

expenditure amounts recorded on the FFRs and the total expenditures recorded in 

its accounting records. However, we were told that the financial reports were 

prepared by the SFS’s Fiscal Manager and Executive Director, who created a 

spreadsheet to calculate the FFRs for each of the first eight quarters. The 

spreadsheet used to calculate the FFRs was not created based on the SFS’s 

accounting system; instead it was created based on information gathered from 

invoices and other expense–related worksheets. We recommend that OVW ensure 

12
 
 

 

 

that the SFS establishes procedures to make sure that its FFRs are accurate and in 

accordance with its accounting records. 

Conclusion 

Based on our audit, we determined that the SFS generally complied with 

requirements related to program performance and budget management. However, 

we identified internal control weaknesses related to the SFS’s failure to maintain 

adequate support for grant expenditures and the lack of written policies and 

procedures. These weaknesses were related to personnel and non-personnel 

expenditures totaling $312,568 that we questioned due to inadequate support. We 

also questioned $39,418 in unallowable costs related to unapproved positions and 

contractor expenses. In addition, the SFS did not accurately submit three Progress 

Reports and eight FFRs, and did not comply with one special condition of the grant. 

As a result, we provide 11 recommendations to OVW to address the deficiencies 

identified during our audit. 

Recommendations 

We recommend that OVW: 

1.	 Ensure that the SFS prepares and submits accurate Progress Reports and 

maintains sufficient documentation to support grant-related 

accomplishments. 

2.	 Ensure that the SFS establish a process to maintain all supporting 

documentation, including intake forms, for data that measures the 

effectiveness of its grant-funded activities. 

3.	 Remedy $2,549 in inadequately supported questioned costs relating to 

grant expenditures. 

4.	 Remedy $21,311 for unallowable salary and associated fringe benefits. 

5.	 Remedy $24,149 in inadequately supported salary and fringe benefits. 

6.	 Remedy $1,085 in inadequately supported fringe benefits (health insurance 

premiums). 

7.	 Ensure that the SFS creates written policies or procedures for contract 

monitoring and procurement as well as maintain all contract related 

documentation. 

8.	 Remedy $284,785 in inadequately supported LGPD and CUPO costs. 

13
 
9.	 Remedy $18,107 in unallowable CUPO and contractor costs: 

a.	 Remedy $4,511 in unallowable Probation Officer costs. 

b. Remedy $7,076 in unallowable counselor costs for payments more than 

the contracted rate. 

c.	 Remedy $6,520 in unallowable counselor costs payments for no-shows 

and cancellations of scheduled victim counseling sessions. 

10.	 Ensure that the SFS creates and implements procedures to ensure that 

federal cash on hand is the minimum needed for disbursements made 

immediately or within 10 days. 

11.	 Ensure that the SFS establishes procedures to make sure that its FFRs are 

accurate and in accordance with its accounting system. 

14
 
 

 

 

APPENDIX 1 

OBJECTIVE, SCOPE, AND METHODOLOGY 

The objective of this audit was to determine whether costs claimed under the 

grant were allowable, supported, and in accordance with applicable laws, 

regulations, guidelines, and terms and conditions. To accomplish this objective, we 

assessed performance in the following areas of grant management: financial 

management, FFRs, budget management and control, drawdowns, expenditures, 

monitoring of sub-recipients and contractors, and program performance. 

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. 

Unless otherwise specified, our audit covered, but was not limited to, 

activities that occurred between the start of grant 2013-WR-AX-0030 on October 1, 

2013, through the start of our fieldwork on January 26, 2016. We tested 

compliance with what we considered to be the most important conditions of the 

grant. Unless otherwise stated in our report, the criteria we audited against are 

contained in the OVW Financial Grants Management Guide, award documents, Code 

of Federal Regulations, and Office of Management and Budget Circulars. 

In conducting our audit, we performed sample testing in six areas, which 

included: program performance, grant financial management, grant expenditures, 

monitoring of contractors, drawdowns, and financial reports. In this effort, we 

employed judgmental sampling design to obtain broad exposure to different facets 

of the grant we reviewed, such as dollar amounts or expenditure categories. We 

reviewed a judgmentally selected sample of transactions that were recorded in the 

SFS’s grant-related accounting records. This included 70 expenditures related to 

grant 2013-WR-AX-0030. Additionally, we selected a judgmental sample of four 

non-consecutive payroll periods. Further, we tested three Progress Reports, eight 

FFRs, and eight drawdown requests. 

We did not test internal controls for the SFS taken as a whole or specifically 

for the grant program administered by the SFS. In addition, we reviewed the 

timeliness and accuracy of FFRs, and Progress Reports; and evaluated the SFS’s 

attempt to accomplish performance of grant objectives. However, we did not test 

the reliability of the financial management system as a whole, nor did we place 

reliance on computerized data or systems in determining whether the transactions 

we tested were allowable, supported, and in accordance with applicable laws, 

regulations, and guidelines. We also performed limited testing of information 

obtained from OJP’s GMS and found no discrepancies. We thus have reasonable 

15
 
confidence in the GMS data for the purposes of our audit. However, the OIG has 

not performed tests of the GMS system specifically, and we therefore cannot 

definitively attest to the reliability of GMS data. 

16
 
 

 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

QUESTIONED COSTS:2 AMOUNT PAGE 

Unsupported Costs: 

Non-personnel Direct Costs $2,549 7 

Personnel and Associated Fringe Benefits Costs $24,149 8 

Fringe Benefits Costs $1,085 8 

LGPD and CUPO Costs $284,785 9 

Total Unsupported Costs $312,568 

Unallowable Costs: 

Personnel and Associated Fringe Benefits Costs $21,311 7 

CUPO Costs – More Than the Agreed Rate of 50 Percent 4,511 9 

Contractor Costs – More Than the Agreed Rate of $29 Per 7,076 9 Hour 

Contractor Costs – Charges for No-Shows and Cancellations 6,520 10 

Total Unallowable Costs $39,418 

GROSS QUESTIONED COSTS: 

$351,986

 Less Duplicative Costs3 <$10,239> 

NET QUESTIONED COSTS $341,747 

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

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

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

funds, or the provision of supporting documentation. 

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

duplicative amounts. 

17
 
 

APPENDIX 3 

SHELTER FROM THE STORM 

RESPONSE TO THE DRAFT AUDIT REPORT4 

November 30, 2016 

David J. Gaschke 

Regional Audit Manager 

San Francisco Regional Audit Officc 

Office o f the Inspector General 

U.S. Department of J ustice 

90 7th Street, Suite 3·100 

San Francisco, CA 94 103 

Dear Mr. Gaschke: 

This leuer is in response to the drafl: audit, received on November 10, 20 16, o f the Office 

on Violence Against Women Program (OVW) Rura l Domestic Violence, Dating Violence, 

Sexua l Assault and Stalking Assistance Program grant number 20 \ 3-WR-AX-0030 awarded to 

Shelte r From the StOI'Tl'l (SFS). 

Before addressing each recommendation, I would like to take this opportunity to provide 

what I believe to be relevant information to the Office of the Inspector General and Office on 

Violence Against Women about SFS and where we nrc today. I think it is important to say that I 

was not involved in the process of, the writing of, or the incorporation of this grant. On 

December 16, 20 14, I was asked to step in as Interim Executive Director and was immediately 

focused on transitioning to not only a new building, but to preserving our services and assuring 

staff was available to assist clients. During the first three months, Our Counselor chose not to 

move forward with us. We were transitioning to outsourc ing our financial processes, and had lost 

our Volunteer & Outreach Coordinator. We were aIL working diligently with clients. While 1 was 

doing the job of three, I was unable 10 really foeus on the duties ofIntcrim Executive Director. l 

was thoughtful with my considerations when 1 chose to move forward with applying for the 

pel'Tl'l anent Executive Director position. Up until June 201 S, when I was offered the permanent 

position, I didn't fee11 ike I had the authority to make major changes that could possibly affect a 

new Executive Director coming in to the organization. Therefore, and for many other reasons 

that I will not disclose in this response, I continued with how things had always been done in the 

past. I did not have the opportunity to really sit down and see how things should have been done, 

nor was I trained on how to pro perly be an Executive Director. What I now know, thanks 10 the 

countless conversations and the patience of our auditors and grant monitor, is thai things were 

not always handled properly. Since then, we have had a chance to correct and move to a more 

prosperous and compliant organization that continues on working to break the cycle of abuse in 

our community. Almost two years after taking over as Interim Executive Director, I feel 

confident that nol only do I have the time, but the knowledge to do my job in an e ffective 

4

 Enclosures referenced in this response were not included in this final report. Redactions 

were made only to the SFS’s response of individuals’ names to protect privacy. 

18
 
manner. I now feel good about asking for assistance when I need it. This audit has been a 

blessing in disguise. 

Reeommendatlons to OVW: 

I. Ensure that the SFS prepares and submits accurate Progress Reports and maintains 

sufficient documentation to support grant-related accomplishments. 

• AGReE: It had come to my attention while being interviewed by II!II!IIII!IIthat the current software (Alice) we were using to track data was duplicating 

services and therefore providing higher numbers that were incorrect. This 

problem has been remedied and the way we process the documentation is done 

more discreetly. We are hoping by January to develop a better process to track the 

actual data needed for reporting purposes. It also came to our attention that OUf 

timesheelS were not accurately reflecting work perfonned by project and we have 

moved 10 a Time and Effort sheet that tracks descriptions of time worked based 

on project. 

2. Ensure that the SFS establish a process to maintain all supporting documentation, 

including intake fonns, fo r data that measures the effectiveness of its grant-funded 

activities. 

• AGREE: The insufficient documentation was my lack of knowledge and 

incorrect infonnation given to me by another Executive Director. We have 

remedied this situation and all intake fonn s are kept on file and will eventually be 

scanned in and backed up to our server for a minimum of fivc years or length of 

time required by grant. 

3. Remedy $2,549 in inadequately supported questioned costs relating to grant expenditures. 

• DISAGREE: Under the direction of our accountant, Guyer & Associates, I was 

told to look at what is available in all of our grants and utilize the nC(;essary 

funding 10 disburse expenditures. Although, I understand more clearly that this 

advice was incorrect, I don't feel like we should pay this back since I was still on 

a learning curve and taking direction where I thought appropriate. Also, some of 

this could have originated under the direction of our fonner Executive Director 

and Fiscal Manager and I had no control over that. 

4. Remedy $21 ,31 1 for unallowable salary and associated fri nge benefits. 

• PARTIALLY DISAGREE: My understanding from the exit teleconference with 

the auditors is that $3,256 of this amount was from employee, who 

was not included in this grant. As this was before my time, I can't substantiate 

this finding nor clarify why this happened, and I therefore agree with only this 

amount of remediation. The remaining $18,055, in my opinion, is directly related 

and accounted for in the grant and this sum is the portion with which I disagree. 

Although my "title" was Interim Executive Director and then Executive Director, 

my role of the Administrative Advocacy Assistant didn't change until September 

2015 and I continued to work with cHents. I also took over the fiscal manager 

responsibilities role upon her leaving and continue 10 this day. 

2 

19
 
5. Remedy S24,149 in inadequately supponed salary and fringe benefits. 

• DISAGREE: I can't clarify how or why things were done by former Executive 

Directors and the Fiscal Manager prior to this audit. And although I am guilty of 

continuing with how things had always been handled, I can attest that as soon as I 

became aware of what was lacking in supported documentation for grants, I 

immediately reached out to our grant monitor for assistance and implemented new 

Time and Effort sheets for all staff. For these reasons, I do not believe we should 

be responsible for paying this sum back. 

6. Remedy $1,085 in inadequately supported fringe benefits (health insurance premiums). 

• DISAGREE: I can't attest to anything being supported correctly prior to March 

1,2015, but since Guyer & Associates took over as our accountants and under my 

supervision, expenditures for fringe benefits were substanliated and correctly 

supported. Therefore, I disagree with this amount. 

7. Ensure that the SFS creates written policies or procedures for contract monitoring and 

procurement as well as maintain all contraet related documentation. 

• AGREED: This recommendation is something that we certainly need assistance 

with and will work closely with OVW should we be approved for future grants. 

8. Remedy 5284,785 in inadequately supported LOPD and CUPO costs. 

• DISAGREE: Again, I can't attest to how things were handled by the former 

Executive Director and Fiscal Manager, and I blindly continued to ask for the 

same type of documentation, or the lack thereof that was required prior to our 

audit. I can attest that the money paid to these contractors was utilized specifically 

for the tasks they were assigned to in this grant. Once I became aware of the 

documentation being inadequate, I immediately made a request of the detective, 

probation officer, and their SUpervisors what I would need from them to move 

forward with payment. From . , r asked for 

invoice, and a detail-statistics sheet on a monthly basis. From 

requested an invoice and a detail-statistics sheet. No payment was sent out to 

them wilhout those items. Although it was lale inlo the grant cycle, I do believe it 

was remedied and therefore no money should be paid back. 

9. Remedy S18, I 07 in unallowable CUPO and contractor costs: 

• Remedy 54,511 in unallowable Probation Officer costs . 

• DISAGREE: In a conversation with our auditors while they were here, I 

specifically remembered one of them saying that we could pay our 

probation officer more than 5(W, if we had the correct documentation. 

Once I started requesting the appropriate documentation, it became clear 

that the probation officer was spending more than 500A of his time 

dedicated to this grant and I expended the actual time spent. 

• Remedy S7,076 in unallowable counselor costs for payments more than the 

contracted rate. 

3 

20
 
• PARTIALLY AGREE: Again, while I can't allest to how things were 

handled by the fonner Executive Director and Fisc;ai Manager, and I agree 

thai this may be an accurate reflection of the COnlract we were able to find, 

I don' t feel it quite fair to put this on the current state of SFS and our 

Board of Directors. The counselor did not move forward with us when we 

transiticned, and therefore there is not one person, employed today, who 

had any control over this situation. 

• Remedy $6,520 in unallowable counselor costs payments for no-shows and 

cancellations of scheduled victim counseling sessions . 

• PARTIALLY AGREE: Again. while I can', attest to how things were 

handled by the fonner Executive Director and Fiscal Manager, and while I 

agree there was nothing stated in the contract we were able to find 

pertaining 10 these payments, I don't feel it quite fair to put this on the 

current state of SFS and our Board of Directors. The eounselor did not 

move forward with us when we transitioned, and therefore there is not one 

person, employed today. who had any control over this situation. 

10. Ensure that the SFS creates and implements procedures to ensure that federal cash on 

hand is the minimum needed for disbursements made immediately or within 10 days. 

• AGREE: I certainly need more training on this and will work closely with OVW 

should we be approved for future grants. 

11 . Ensure that SFS establishes procedures to make sure that its FFRs are accurate alld ill 

accordance with its aceounting system. 

• AGREE: I came into this positioll blind and had no assistance with preparing 

reports, including financials. I taught myself and see now thai I had been filling 

them out incorrectly. I certainly need more training on this conCern and will work 

closely with OVW should we be approved for future grants. 

Sincerely. 

Mindy 

U~~~ Mowery 

Executive Director 

Enclosure 

Regional Audit Manager, Office of Inspector General, DOJ 

Audit Liaison, Office on Violence Against Women 

I Board of Directors 

V;,,,-'Ch,,;,. Board of Directors 

La Grande Police Department 

Conununity Corrections 

La Grande Police Department 

Union County Community Corrections 

4 

21
 
APPENDIX 4 

OFFICE ON VIOLENCE AGAINST WOMEN 

RESPONSE TO THE DRAFT AUDIT REPORT 

22
 

u.s. Department of Justice 

Office on Violence Against Women 

Washington. DC 20DO 

December 7. 2016 

MEMORANDUM 

TO: David J. Gaschke 

Regional Audit Manager 

San Francisco Regional Audit Office 

FROM: Bea Hanson -t\~ Principal DepuW~reetor 

Office on Violence Against Women 

Rodney 

Audit Liaison/Slaff 

Samuels ~ Accountant 

Office on Violence Against Women 

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

Women Grant Awarded to Shelter From the Storm. Incorporated 

Island City. Oregon 

This memorandum is in response to your correspondence dated November 10. 2016 transmitting 

the above draft audit report for Shelter From the Storm. Incorporated (SFS). We consider the 

subject report resolved and request written acceptance oftnis action from your office. 

The report contains II recommendations which include $34 1.747 in nel questioned costs. OVW 

is committed 10 working with the grantee to address and bring these recommendations to a close 

as quickly as possible. The following is our analysis ofthe audit recommendations. 

1. Ensure tba t tbe SFS prepares and submits accurate P rogrus Reports and Maintains 

sufficient documentation to support grant-related accomplisbment.s unused grant funds 

a re d eobligated. 

OVW does agree with the recommendation. We will coordinate with the grantee to 

en",ure that they p repare and submit accurate P rog...,,,,, Reports and Maintains 

sufficient documentation to support grant-related accomplislunents unused grant funds 
are deobligated. 

2. Ensure that the SFS establish a process to maintain all supporting documentation, 

including intake forms, for data that measures the effectiveness of its grant.funded 

activities. 

OVW does agree with the recommendation. We will coordinate with the grantee to ensure 

that they establish a process to maintain all supporting documentation, 

including intake forms, for data that measures the effectiveness of its grant-funded 

activities. 

3. Remedy 52,549 in inadequately supported questioned costs relating to grant 

expenditures. 

Even though the grantee is in disagreement with the recommendation, OVW will coordinate 

with them to remedy S2,549 in inadequately supported questioned costs relating to grant 

expenditures. 

4. Remedy S21,311 for unallowable salary and assodated fringe benefits. 

Even though the grantee is in disagreement with the recommendation, OVW wit! coordinate 

with the grantee to remedy $21,311 for unallowable salary and associated fringe benefits. 

5. Remedy S24,149 in inadequately supported salary and fringe benefits. 

Even though the grantee is in disagreement with the recommendation, OVW wilt coordinate 

with the grantee to ensure that they remedy S24, 149 in inadequately supported salary and 

fringe benefits. 

6. Remedy $1,085 in inadequately supported fringe benefits (health insurance premiums). 

Even though the grantee is in disagreement with the recommendation, OVW wilt coordinate 

with the grantee to ensure the they remedy 51,085 in inadequately supported fringe benefits 

(health insurance premiums). 

7. Ensure that the SFS creates wriHen policies or procedures for contract monitoring and 

procurement as well as maintain all contract related documentation. 

OVW does agree with the recommendation. We wilt coordinate with the grantee to 

ensure that they create written policies or procedures for contract monitoring and 

procurement as well as maintain all contract related documentation. 

8. Remedy the $284,785 in inadequately supported LGPD and CUPD costs. 

Even though the grantee is in disagreement with the recommendation, OVW will coordinate 

with the grantee to remedy the $284,785 in inadequately supported LGPD and CUPO costs. 

23
 
9. Remedy tbe $18,107 in unallowable CUPO and contractor costs. 

a. Remedy $4,511 in unallowable Probation Officer costs. 

b. Remedy $7.076 in unallowable counselor costs for payments more than the 

contractor rale. 

c. Remedy $6,520 in unallowable counselor costs payments for no-shows and 

cancellations of scheduled victim counseling sessions. 

Even though the grantee is in disagreement with the recommendation, OVW will coordinate 

with the grantee remedy the $18, I 07 in unallowable CUPO and contractor costs. 

10. Ensure that the SFS creates and implements procedures to ensure that federal cash on 

hand is the minimum needed for disbursements made immediately or within 10 days. 

OVW agrees with the recommendation. We will coordinate with the grantee to ensure that 

they create and implement procedures to ensure that federal cash on hand is the minimum 

needed for disbursements made immediately or within 10 days. 

11. Ensure that the SFS establishes procedures to ma ke sure that its FFRs are accurate 

and in accordance with its accounting systems. 

OVW agrees with the recommendation. We will coordinate with the grantee to ensure that 

the SFS establishes procedures to make sure that its FFRs are accurate and in accordance 

with its accounting systems. 

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

questions or require additional infonnation, please contact Rodney Samuels of my staff at 

(202) 514-9820. 

cc Donna Simmons 

Associate Director, Grants Financial Management Division 

Office on Violence Against Women (OVW) 

Louise M. Duhamel, Ph.D. 

Acting Assistant Director 

Audit Liaison Group 

Justice Management Division 

Debbie Bright 

Program Manager 

Office on Violence Against Women (OVW) 

24
 
 

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 SFS and OVW for their 

review and comment. The responses from the SFS and the OVW are incorporated 

in Appendix 3 and Appendix 4, respectively, of this final report. In response to our 

draft audit report, OVW demonstrated proposed actions to address our 

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

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

necessary to close the report. 

OIG Analysis of the SFS’s Response 

In its response, the SFS stated that the organization in December 2014 was 

transitioning from one manager to another and moving the organization to a new 

location. These changes had the new Executive Director performing multiple job 

functions. Therefore, the Executive Director continued to perform tasks as they 

had always been done and did not have time to be able to focus on what changes 

needed to be made to correct any errors made by previous staff or management. 

We understand and appreciate that the SFS and the Executive Director may have 

experienced difficulties during the transition, but also note that as recipients of 

federal funds, organizations are responsible for ensuring compliance with grant 

requirements throughout the award period, including periods of transition. We 

further note that besides providing written grant requirements in the form of its 

OVW Financial Grants Management Guide, OVW also provided training on federal 

grant regulations and requirements. For example, we note that the current 

Executive Director attended OVW’s grantee orientation training in 2014 where grant 

requirements were discussed. Further, grant recipients can call their OVW grant 

manager to ask questions on how to properly handle grant-related transactions. 

We support SFS’s statements in its response expressing its dedication to complying 

with related grant requirements in the future. 

Recommendations: 

1.	 Ensure that the SFS prepares and submits accurate Progress 

Reports and maintains sufficient documentation to support grantrelated accomplishments. 

Resolved. OVW agreed with our recommendation. OVW stated in its 

response that it will coordinate with the SFS to ensure that the SFS will 

prepare and submit accurate Progress Reports and maintain sufficient 

documentation to support grant-related accomplishments. 

25
 
 

 

The SFS concurred with our recommendation and stated in its response 

that the software system the SFS used to track data for victim services was 

duplicating the count for the number of victims that were provided services, 

and therefore, the system provided incorrect data. The SFS explained this 

problem has been remedied and the method the SFS uses to process 

information is done more discreetly. In January 2017, the SFS hopes to 

develop a better process to track the actual data needed for reporting 

purposes. 

This recommendation can be closed when we receive evidence that the 

SFS’s new process ensures that Progress Reports are competed accurately 

and that it will maintain sufficient documentation to support grant-related 

accomplishments. 

2.	 Ensure that the SFS establish a process to maintain all supporting 

documentation, including intake forms, for data that measures the 

effectiveness of its grant-funded activities. 

Resolved. OVW agreed with our recommendation. OVW stated in its 

response that it will coordinate with the SFS to ensure that the SFS 

establishes a process to maintain all supporting documentation, including 

intake forms, for data that measures the effectiveness of its grant-funded 

activities. 

The SFS concurred with our recommendation and stated in its response 

that the insufficient documentation was caused by the SFS Executive 

Director’s lack of knowledge and incorrect information provided by the 

previous Executive Director. The SFS explained it has remedied the 

situation and all intake forms are now kept on file. It will eventually scan in 

all intake forms and back them up to its server for a minimum of 5 years or 

the length of time required by the grant. 

This recommendation can be closed when we receive documentation that 

the SFS has created a process to maintain all supporting documentation, 

including intake forms, for data that measures the effectiveness of its 

grant-funded activities. 

3.	 Remedy $2,549 in inadequately supported questioned costs relating 

to grant expenditures. 

Resolved. In its response, OVW did not state specifically whether it agreed 

with the recommendation. However, OVW stated that it will coordinate 

with the SFS to remedy $2,549 in inadequately supported questioned costs 

relating to grant expenditures. We determined that OVW’s proposed 

actions will advance the resolution of the recommendation. As a result, we 

consider this recommendation resolved. 

26
 
 

The SFS did not concur with our recommendation. In its response, the SFS 

stated that its Executive Director followed the accountant’s direction to look 

at all of its grants to identify available funds and utilize those funds for 

necessary expenditures. Additionally, the SFS stated that its Executive 

Director was still learning the duties of her new position and thought the 

directions provided by the SFS’s accountant was appropriate. However, 

after our audit, the SFS Executive Director understood that the 

accountant’s advice was incorrect. The SFS further stated that some of the 

inadequately supported questioned costs relating to grant expenditures 

could have originated under the direction of the previous SFS Executive 

Director and Fiscal Manager, which the current SFS Executive Director had 

no control over. Therefore, the Executive Director believes the SFS should 

not have to pay back $2,549 in questioned costs. 

As stated in the report, 9 transactions totaling $2,549 related to insurance, 

travel and training, office supplies, and printing that were inadequately 

supported because the SFS used an unsupported methodology for the 

allocation of expenditures to the grant. These indirect cost expenditures 

should have been allocated to the grant by an approved indirect cost rate, 

or by a supported and logical methodology. As the SFS admits, it allocated 

expenditures to their funding streams based on availability of funds and not 

based on a supportable methodology. SFS admitted that this is not the 

proper method for handling these expenditures. In addition, the SFS stated 

that it does not believe it has to pay back the $2,549 in questioned costs. 

We did not recommend that the SFS pay back the questioned costs, but 

rather that OVW remedy the questioned costs, which may include the SFS 

paying back funds as one of various methods to remedy questioned costs, 

but also includes other remedies such as offset, waiver, or the provision of 

supporting documentation. 

This recommendation can be closed when we receive evidence OVW has 

remedied the $2,549 in inadequately supported questioned costs relating to 

grant expenditures. 

4.	 Remedy $21,311 for unallowable salary and associated fringe 

benefits. 

Resolved. In its response, OVW did not state specifically whether it agreed 

with the recommendation. However, OVW stated that it will coordinate 

with the SFS to remedy $21,311 for unallowable salary and associated 

fringe benefits. We determined that OVW’s proposed actions will advance 

the resolution of the recommendation. As a result, we consider this 

recommendation resolved. 

The SFS partially concurred with our recommendation and stated in its 

response that it agrees with $3,256 in questioned costs that were disbursed 

by the grant under the previous SFS Executive Director. However, it 

27
 
 

 

disagrees with the remaining $18,055 in questioned costs for unallowable 

salary and associated fringe benefits, as these costs were directly related to 

the grant. The SFS stated that its Executive Director was performing more 

than one function in 2015 to include the position of Administrative 

Advocacy Assistant. 

The Executive Director’s and Advocate’s positions were not included in the 

approved grant budget nor were budget modifications obtained by the SFS 

through Grant Adjustment Notices. Without approval from OVW, the 

Executive Director’s and Advocate’s positions were unapproved and thus, 

unallowable. SFS did not provide any supporting documentation to support 

that the Executive Director who was promoted in December 2014 was also 

continuing her prior full-time role as Administrative Advocacy Assistant. 

This recommendation can be closed when we receive documentation that 

OVW has remedied the $21,311 in unallowable salary and associated fringe 

benefits. 

5.	 Remedy $24,149 in inadequately supported salary and fringe 

benefits. 

Resolved. In its response, OVW did not state specifically whether it agreed 

with the recommendation. However, OVW stated that it will coordinate 

with the SFS to remedy $24,149 in inadequately supported salary and 

fringe benefits. We determined that OVW’s proposed actions will advance 

the resolution of the recommendation. As a result, we consider this 

recommendation resolved. 

The SFS did not concur with our recommendation and stated in its response 

that it is unable to clarify how or why things were done by the previous 

Executive Director and the previous Fiscal Manager. The current SFS 

Executive Director continued how things had always been handled 

previously until she became aware of the lacking supporting documentation 

and reached out to SFS’s OVW grant manager for assistance to implement 

new Time and Effort sheets for all staff. The SFS has implemented a Time 

and Effort sheet that tracks descriptions of time worked by project. Based 

on this information, the SFS stated that it did not believe it should pay back 

the amount that we questioned. 

The reforms that SFS implemented to its Time and Effort sheet may help 

ensure appropriate personnel charges in the future, however the $24,149 in 

costs questioned in this recommendation involved expenditures incurred 

prior to the implementation of that policy change. As a result, we do not 

have adequate support for these charges. The SFS’s timesheets and 

payroll records we reviewed did not break down work performed by project. 

Without a breakdown by project, the SFS lacked adequate support to 

substantiate the amount spent on personnel costs for a particular grant as 

28
 
 

 

 

opposed to other programs. In addition, the SFS stated that it does not 

believe it has to pay back the $24,149 in questioned costs. We did not 

recommend that the SFS pay back the questioned costs, but rather that 

OVW remedy the questioned costs, which may include the SFS paying back 

funds as one of various methods to remedy questioned costs, but also 

includes other remedies such as offset, waiver, or the provision of 

supporting documentation. 

This recommendation can be closed when we receive documentation that 

OVW has remedied the $24,149 in inadequately supported salary and fringe 

benefits. 

6.	 Remedy $1,085 in inadequately supported fringe benefits (health 

insurance premiums). 

Resolved. In its response, OVW did not state specifically whether it agreed 

with the recommendation. However, OVW stated that it will coordinate 

with the SFS to remedy $1,085 in inadequately supported fringe benefits. 

We determined that OVW’s proposed actions will advance the resolution of 

the recommendation. As a result, we consider this recommendation 

resolved. 

The SFS did not concur with our recommendation and stated in its response 

that it cannot attest to the support for expenditures for fringe benefits 

handled by the previous Executive Director. However, since the current 

Executive Director took over and the SFS hired a CPA firm, she believes the 

fringe benefits are correctly supported. 

In our review of fringe benefits, we found a transaction that did not have a 

logical and supportable allocation methodology for $423 and another fringe 

benefit transaction that did not have supporting documentation for $662. 

SFS has not provided adequate documentation for those expenditures. 

Despite its change in leadership, SFS was responsible for abiding by the 

grant terms and conditions for the entire award period. 

This recommendation can be closed when we receive evidence that OVW 

has remedied the $1,085 in inadequately supported fringe benefits. 

7.	 Ensure that the SFS creates written policies or procedures for 

contract monitoring and procurement as well as maintain all 

contract related documentation. 

Resolved. OVW agreed with our recommendation. OVW stated in its 

response that it will coordinate with the grantee to ensure that they create 

written policies or procedures for contract monitoring and procurement as 

well as maintain all contract related documentation. 

29
 
 

 

 

 

The SFS concurred with our recommendation and stated that it needs 

assistance to implement this recommendation and it will work closely with 

OVW should it be approved for future grants. 

This recommendation can be closed when we receive documentation 

evidencing that the SFS has established procurement procedures for the 

proper monitoring of its contractors and the maintenance of all contractrelated documentation to ensure compliance with federal regulations. 

8. Remedy $284,785 in inadequately supported LGPD and CUPO costs. 

Resolved. In its response, OVW did not state specifically whether it agreed 

with the recommendation. However, OVW stated that it will coordinate 

with the SFS to remedy $284,785 in inadequately supported LGPD and 

CUPO costs. We determined that OVW’s proposed actions will advance the 

resolution of the recommendation. As a result, we consider this 

recommendation resolved. 

The SFS did not concur with our recommendation and stated in its response 

that the SFS Executive Director continued to receive insufficient documents 

from the LGPD and CUPO, similar to what the previous Executive Director 

and Fiscal Manager accepted from the LGPD and CUPO. In addition, the 

SFS stated that its Executive Director can attest that the money paid to 

LGPD and CUPO was utilized specifically for the tasks they were assigned to 

in this grant. Moreover, when the SFS Executive Director became aware of 

the inadequate documents, she requested additional documentations. 

Additional documentation requested from LGPD and CUPO included a 

mileage log, invoice, and detail statistics. As a result, the SFS stated that it 

believed it has remedied this recommendation and therefore it should not 

pay back the questioned costs. 

As stated in the report, we reviewed 16 transactions (8 LGPD and 8 CUPO 

invoices), totaling $284,785, that were related to the Detective’s and 

Probation Officer’s grant-related positions. We found that the SFS paid 

these invoices without requiring support for the hours worked. We also 

confirmed with both the Detective and Probation Office that they at times 

perform duties that are not grant-related. Without supporting 

documentation, the SFS was unable to confirm and document how much 

time the LGPD and CUPO spent on grant-related activities. The additional 

documentation that SFS stated it received from LGPD and CUPO was not 

provided to the OIG, and we do not have adequate support for these 

expenditures. 

In addition, the SFS stated that it does not believe it has to pay back the 

$284,785 in questioned costs. We did not recommend that the SFS pay 

back the questioned costs, but rather that OVW remedy the questioned 

30
 
 

 

 

 

 

costs, which may include the SFS paying back funds as one of various 

methods to remedy questioned costs. 

This recommendation can be closed when we receive documentation that 

OVW has remedied $284,785 in inadequately supported LGPD and CUPO 

costs. 

9. Remedy $18,107 in unallowable CUPO and contractor costs: 

a. Remedy $4,511 in unallowable Probation Officer costs. 

Resolved. In its response, OVW did not state specifically whether it 

agreed with the recommendation. However, OVW stated that it will 

coordinate with the SFS to remedy $18,107 in unallowable CUPO and 

contractor costs. We determined that OVW’s proposed actions will 

advance the resolution of the recommendation. As a result, we consider 

this recommendation resolved. 

The SFS did not concur with our recommendation and stated in its 

response that its Executive Director followed the accountant’s direction 

that SFS could be reimbursed for more than 50 percent of the CUPO 

Probation Officer’s salary with appropriate supporting documentation. 

The SFS reviewed appropriate documentation to justify the expenditures 

for the Probation Officer costs. After its review, the SFS determined it 

expended the correct amount for the Probation Officer. 

As stated in the report, we found that the SFS paid more than 

50 percent of the Probation Officer’s salary on five occasions; the 

overage totaled $4,511. The SFS was only approved in the grant 

budget to reimburse the CUPO for 50 percent of the Probation Officer’s 

salary and the SFS did not have sufficient supporting documentation for 

these expenditures. The SFS has not provided us with additional 

documentation or explained the additional costs. 

This recommendation can be closed when we receive documentation 

that OVW has remedied $4,511 in unallowable Probation Officer costs. 

b. Remedy $7,076 in unallowable counselor costs for payments 

more than the contracted rate. 

Resolved. In its response, OVW did not state specifically whether it 

agreed with the recommendation. However, OVW stated that it will 

coordinate with the SFS to remedy $18,107 in unallowable CUPO and 

contractor costs. We determined that OVW’s proposed actions will 

advance the resolution of the recommendation. As a result, we consider 

this recommendation resolved. 

31
 
 

 

 

The SFS partially concurred with our recommendation and stated in its 

response that the contractor that had filled the counselor’s position did 

not move with the SFS when it relocated. The SFS further stated it 

believes this is not fair to the current state of the SFS and its Board of 

Directors for it to be responsible for the questioned costs or what 

occurred with these costs. The SFS stated that no one employed today 

had any control over these questioned costs. 

As stated in the report, the SFS paid the contracted counselor a rate of 

$40 per hour, which is $11 more than the signed contract amount of 

$29 per hour, more than 800 times for a total of $7,076. Further, the 

SFS agreed to comply with the terms and conditions of the OVW grant 

when it accepted the grant award. Despite its change in leadership, SFS 

was responsible for abiding by the grant terms and conditions for the 

entire award period. 

This recommendation can be closed when we receive documentation 

that OVW has remedied $7,076 in unallowable counselor costs for 

payments in excess of the contracted rate. 

c.	 Remedy $6,520 in unallowable counselor costs payments for noshows and cancellations of scheduled victim counseling sessions. 

Resolved. In its response, OVW did not state specifically whether it 

agreed with the recommendation. However, OVW stated that it will 

coordinate with the SFS to remedy $18,107 in unallowable CUPO and 

contractor costs. We determined that OVW’s proposed actions will 

advance the resolution of the recommendation. As a result, we consider 

this recommendation resolved. 

The SFS partially concurred with our recommendation and stated in its 

response that the contractor who had filled the counselor’s position did 

not move with the SFS when it relocated and that no one employed 

within the SFS today had any control over these questioned costs. The 

SFS further stated that it feels this is not fair to the current state of the 

SFS and its Board of Directors for it to be responsible for the questioned 

costs or what occurred with these costs. 

As stated in the report, the SFS paid the contracted counselor $6,520 

for 163 cancelled and no-show counseling sessions. According to the 

contract, the SFS should have paid only for completed work; the 

contract had no provision for the counselor to be paid for no-shows or 

cancelled sessions. Further, just because previous employees of the 

SFS may not have complied with the terms and conditions of the OVW 

grant, it does not absolve the SFS as an organization and grantee from 

being responsible for the associated questioned costs. The SFS agreed 

to comply with the terms and conditions of the OVW grant when it 

32
 
 

 

accepted the grant award. Despite its change in leadership, SFS was 

responsible for abiding by the grant terms and conditions for the entire 

award period. 

This recommendation can be closed when we receive documentation 

that OVW has remedied $6,520 in unallowable counselor costs for 

payments for no-shows and cancellations of scheduled victim counseling 

sessions. 

10. Ensure that the SFS to creates and implements procedures to 

ensure that federal cash on hand is the minimum needed for 

disbursements made immediately or within 10 days. 

Resolved. OVW agreed with our recommendation. OVW stated in its 

response that it will coordinate with the SFS to ensure that they create and 

implement procedures to ensure that federal cash on hand is the minimum 

needed for disbursements made immediately or within 10 days. 

The SFS concurred with our recommendation and stated in its response 

that the SFS needs more training in this particular area and that it will work 

closely with OVW should it be approved for future grants. 

This recommendation can be closed when we receive documentation of the 

SFS policy changes that ensure that the SFS keeps federal cash on hand to 

a minimum needed in accordance with federal regulations. 

11. Ensure that the SFS establishes procedures to make sure that its 

FFRs are accurate and in accordance with its accounting system. 

Resolved. OVW agreed with our recommendation. OVW stated in its 

response that it will coordinate with the SFS to ensure that they establish 

procedures to make sure that its FFRs are accurate and in accordance with 

its accounting system. 

The SFS concurred with our recommendation and stated in its response 

that the SFS need more training on this concern and will work closely with 

OVW should it be approved for future grants. 

This recommendation can be closed when we receive documentation that 

the SFS has made policy changes to ensure that its FFRs are accurate and 

in accordance with its accounting system. 

33
 
   

The Department of Justice Office of the Inspector General 

(DOJ OIG) is a statutorily created independent entity 

whose mission is to detect and deter waste, fraud, 

abuse, and misconduct in the Department of Justice, and 

to promote economy and efficiency in the Department’s 

operations. Information may be reported to the DOJ 

OIG’s hotline at www.justice.gov/oig/hotline or 

(800) 869-4499. 

Office of the Inspector General 

U.S. Department of Justice 

www.justice.gov/oig 

REDACTED – FOR PUBLIC RELEASE