ORT – NOT FOR PUBLIC RELEA

Office of the Inspector General 

U.S. Department of Justice 

Audit of the 

Office of Justice Programs 

Office for Victims of Crime 

Assistance Grants Awarded to the 

Office of Victim Services 

and Justice Grants, 

Washington, D.C. 

Audit Division GR-30-17-001 DRAFT AUDIT REP February 2017 SE 
 

 

 

 

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

OFFICE FOR VICTIMS OF CRIME
 

ASSISTANCE GRANTS AWARDED TO THE OFFICE OF VICTIM 

SERVICES AND JUSTICE GRANTS, WASHINGTON, D.C.
 

EXECUTIVE SUMMARY 

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

completed an audit of three Victim Assistance Formula grants totaling $7,100,587 

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

to the District of Columbia’s Office of Victim Services and Justice Grants (OVSJG). 

These OVC awards, grants 2013-VA-GX-0039, 2014-VA-GX-0025, and 2015-VAGX-0047, provided funds through the Victims of Crime Act (VOCA) to enhance 

crime victim services throughout Washington, D.C. 

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

implemented its crime victim assistance program. To accomplish this objective, we 

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

assistance award planning, (2) program requirements and performance reporting, 

(3) grant financial management, and (4) monitoring of subrecipients. 

Overall, we found that the OVSJG used its VOCA victim assistance grant 

funding to enhance services for crime victims. Also, the audit did not identify 

significant concerns regarding the OVSJG’s annual performance reports, drawdown 

process, federal financial reports, or subrecipient monitoring. However, we found 

that the OVSJG could make several improvements in its management of these 

grants, including improving controls over the funds allocated for grant 

administration. We also determined that the OVSJG did not comply with essential 

award conditions related to use of the 5 percent of each award that it could spend 

on administrative purposes. Specifically, we found that the OVSJG based its 

timekeeping and payroll procedures on budget projections and did not keep records 

based on the actual time its employees worked on the VOCA grants. We therefore 

question all $152,807 in unsupported personnel costs the OVSJG charged to the 

grants. We further found that the OVSJG needs to implement more stringent 

controls on how it charges general administrative office expenses to the VOCA 

grants. In addition, we determined that OVSJG’s oversight of the subrecipient 

match required by VOCA did not align with the guidelines governing the program, 

nor did OVSJG reporting on the match amounts correspond with the contributions 

made by its subrecipients. We also tested expenditures at the subrecipient level 

and identified $1,500 in unallowable health allowance costs. 

Our report contains eight recommendations to OJP, detailed later in this 

report. Appendix 1 contains a discussion of our audit objective, scope, and 

methodology, and our Schedule of Dollar-Related Findings appears in Appendix 2. 

In addition, we requested a response to our draft audit report from the OVSJG and 

OJP, and their responses are appended to this report as Appendix 3 and 4, 

respectively. Our analysis of both responses, as well as a summary of actions 

necessary to close the recommendations, can be found in Appendix 5 of this report. 

i 
AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

OFFICE FOR VICTIMS OF CRIME
 

ASSISTANCE GRANTS AWARDED TO THE OFFICE OF VICTIM 

SERVICES AND JUSTICE GRANTS, WASHINGTON, D.C. 

TABLE OF CONTENTS 

Background ................................................................................................. 1 

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

VOCA State Victim Assistance Award Plan ........................................................ 2 

Subaward Allocation Plan...................................................................... 3 

Selection Process for Victim Assistance Subawards ................................... 3 

Subaward Requirements ....................................................................... 4 

Program Requirements and Performance Reporting ........................................... 4 

Priority Areas Funding Requirement ........................................................ 4 

Annual Performance Reports ................................................................. 5 

Compliance with Special Conditions ........................................................ 6 

Grant Financial Management .......................................................................... 6 

Drawdowns ......................................................................................... 6 

Expenditures....................................................................................... 7 

Administrative Expenditures ......................................................... 7 

Subrecipient Expenditures.......................................................... 10 

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

Financial Reporting ............................................................................ 12 

Monitoring of Subrecipients .......................................................................... 12 

Financial Monitoring ........................................................................... 13 

Performance Monitoring...................................................................... 14 

Conclusion................................................................................................. 15 

Recommendations ...................................................................................... 15 
APPENDIX 1: OBJECTIVE, SCOPE, AND METHODOLOGY .................................. 17 

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

APPENDIX 3: OFFICE OF VICTIM SERVICES AND JUSTICE GRANTS RESPONSE TO
 

THE DRAFT AUDIT REPORT ................................................................. 19 

APPENDIX 4: OFFICE OF JUSTICE PROGRAMS RESPONSE TO THE DRAFT AUDIT 

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

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

ACTIONS NECESSARY TO CLOSE THE REPORT ....................................... 27 
 

 

 

 

 

 

AUDIT OF THE OFFICE OF JUSTICE PROGRAMS 

OFFICE FOR VICTIMS OF CRIME
 

ASSISTANCE GRANTS AWARDED TO THE OFFICE OF VICTIM 

SERVICES AND JUSTICE GRANTS, WASHINGTON, D.C.
 

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

completed an audit of three victim assistance grants awarded by the Office of 

Justice Programs (OJP) Office for Victims of Crime (OVC) to the Washington, D.C., 

Office of Victim Services and Justice Grants (OVSJG). The OVC awards victim 

assistance grants to state administering agencies under the Victims of Crime Act 

(VOCA).1

 As the Washington, D.C., state administering agency for this program, 

the OVSJG received these VOCA assistance program grants according to a 

population-based formula. As of August 2016, the OVSJG had received three VOCA 

assistance grants totaling $7,100,587, shown in Table 1. 

Table 1 

VOCA Assistance Program Grants Awarded to the OVSJG 

Fiscal Years 2013 – 2015 

Award Number Award 

Date 

Project Start 

Date 

Project End 

Date 

Award 

Amount 

2013-VA-GX-0039 08/27/2013 10/01/2012 09/30/2016 $1,291,657 

2014-VA-GX-0025 07/08/2014 10/01/2013 09/30/2017 1,365,626 

2015-VA-GX-0047 08/25/2015 10/01/2014 09/30/2018 4,443,304

 Total: $7,100,587 

Source: OJP’s Grants Management System (GMS) 

Background 

The OVC annually distributes to states and territories proceeds from the 

Crime Victims Fund (CVF), which holds the fines, penalties, and bond forfeitures of 

convicted federal offenders. The amount of funds that the OVC may distribute each 

year depends largely upon the total CVF deposits made during the preceding year 

and limits set by Congress. In FY 2015, Congress significantly raised the previous 

year’s cap on CVF disbursements, which more than tripled the available funding 

from $745 million to $2.36 billion. As a result, the OVC increased its annual VOCA 

assistance formula grant to the OVSJG from $1.37 million in FY 2014 to $4.4 million 

in FY 2015. 

The OVSJG coordinates and funds programs that seek to serve crime victims 

and prevent crimes throughout Washington, D.C. In this role, the OVSJG 

administers grants to organizations and coordinates multi-disciplinary and 

comprehensive efforts to support crime victims. Such efforts include: (1) providing 

transitional housing for victims of domestic violence; (2) coordinating with area 

hospitals to ensure that victims receive medical forensic services; (3) maintaining 

1

 42 U.S.C. § 112.10603 (2016). 

1 
 

 

outreach programs; and (4) providing crisis intervention services and advocacy for 

attempted victims of homicide, secondary victims of homicide, and victims of sexual 

assault, domestic violence, child abuse, and youth violence. 

OIG Audit Approach 

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

implemented Washington, D.C.’s crime victim assistance program. To accomplish 

this objective, we assessed the OVSJG’s grant management performance in the 

following areas: (1) victim assistance award planning, (2) program requirements 

and performance reporting, (3) grant financial management, and (4) monitoring of 

subrecipients. Our scope encompassed Victims of Crime Act (VOCA) victim 

assistance formula grants 2013-VA-GX-0039 (2013 award), 2014-VA-GX-0025 

(2014 award), and 2015-VA-GX-0047 (2015 award) to the OVSJG. 

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 assistance program guidelines (VOCA 

guidelines), and the OJP and DOJ Financial Guides as our primary criteria.2 We 

also reviewed relevant OVSJG policy and procedures and interviewed OVSJG 

personnel to determine how they distributed and administered the VOCA funds. 

We further obtained and reviewed OVSJG and subrecipient records reflecting 

grant activity.3 

VOCA State Victim Assistance Award Plan 

VOCA victim assistance awards should enhance crime victim services through 

competitive subawards to local community-based organizations. Primary recipients 

of these grants at the state or territory level must distribute the majority of the 

funding to local organizations that provide direct services to victims. OVC 

guidelines define eligible services as those efforts that: (1) respond to the 

emotional and physical needs of crime victims, (2) assist primary and secondary 

victims of crime to stabilize their lives after a victimization, (3) assist victims to 

understand and participate in the criminal justice system, and (4) provide victims of 

crime with a measure of safety and security. Based on the program guidelines, 

state administering agencies must give priority to victims of sexual assault, 

domestic abuse, and child abuse. Under this program, state administering agencies 

must also make funding available for previously underserved populations of violent 

crime victims. The OVC distributes VOCA victim assistance grants to the state 

2 The OJP Financial Guide governs the FY 2013 and 2014 grants in our scope, while the 

revised 2015 DOJ Financial Guide applies to the FY 2015 award. The revised DOJ guide reflects 

updates to comply with the Uniform Grant Guidance, 2 C.F.R. part 200. 

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. 

2 
 

 

 

 

 

administering agencies, which have the discretion to select subrecipients from 

among eligible organizations that provide direct services to crime victims.4 

Subaward Allocation Plan 

In response to the significant increase in CVF available funding, the OVC’s 

FY 2015 VOCA Victim Assistance Formula Solicitation required that state and 

territory applicants submit a subrecipient funding plan that detailed their efforts to 

identify additional victim service needs, as well as subaward strategies to spend the 

substantial increase in available VOCA funding. In an attachment with its 

application for VOCA assistance program grant 2015-VA-GX-0047, OVSJG indicated 

it would base its subaward plan on the Washington, D.C., Mayor's Community 

Stabilization Plan. This Community Stabilization Plan prioritized developing and 

expanding services for Washington, D.C., victims of attempted homicide and 

secondary victims of homicide. In addition, the OVSJG used the increased funding 

to launch the D.C. Victim Assistance Hotline in April 2016 and increased the 

capacity for an interpreter bank to serve populations facing language barriers. The 

OVSJG also used this increase in FY 2015 VOCA funding to make larger awards to 

existing OVSJG service providers. 

 Selection Process for Victim Assistance Subawards 

To assess how the OVSJG implemented its victim assistance program, we 

identified the steps that the OVSJG took to inform, evaluate, and select 

subrecipients for VOCA funding. The OVSJG first published a Notice for Funding 

Availability and a Request for Application (RFA) to solicit applications from possible 

VOCA subrecipients. Once it received applications, the OVSJG then organized a 

peer reviewer panel composed of independent victim services subject matter 

experts to evaluate and score applications. OVSJG grant manager specialists also 

performed an internal evaluation of the applications, taking into consideration their 

historical knowledge and professional experience with the potential subrecipients. 

After all the applications were peer reviewed and internally evaluated, the 

OVSJG’s Director selected the final subrecipients by considering both peer review 

results and grant manager specialist recommendations. As of May 2016, we found 

that the OVSJG had made subawards to four organizations with 2013 award funds, 

four organizations with 2014 award funds, and eight organizations with 2015 award 

funds.5 

4

 So long as a state administering agency allocates at least 10 percent of available funding to 

victim populations in each of the victim categories of sexual assault, domestic abuse, child abuse, and 

underserved victims, a state administering agency has the sole discretion in determining the amount 

of funds each subrecipient receives. 

5

 For the FY 2013 and FY 2014 grants, certain subrecipients received multiple VOCA 

subawards to fund distinct crime victim projects. In addition, some subrecipient organizations were 

repeat recipients and thus received successive annual VOCA subawards. 

3 
 

Subaward Requirements 

State administering agencies must adequately communicate VOCA 

requirements to their subrecipients. We reviewed OVSJG’s RFAs, which conveyed 

the VOCA-specific award limitations, applicant eligibility requirements, eligible 

program areas, restrictions on use of funds, and reporting requirements to potential 

applicants. The OVSJG RFAs also required that applicants certify they understood 

the VOCA program details, organization eligibility requirements, definition of 

allowable costs for direct services, and descriptions of other allowable and nonallowable costs and services. A responsible official from each subrecipient 

organization must certify that he or she agreed to comply with the VOCA guidelines 

as a condition for receiving a subaward. 

Overall, we determined that the OVSJG identified and planned to meet 

additional victim service needs with its increased FY 2015 funding. We did not 

identify any issues with its process to select subrecipients and found that the 

OVSJG adequately communicated to its subrecipients applicable VOCA 

requirements. 

Program Requirements and Performance Reporting 

To determine whether the OVSJG distributed VOCA assistance program funds 

to local community-based organizations to serve crime victims or enhance crime 

victim services, we reviewed OVSJG’s distribution of grant funding via subawards 

among local direct service providers. We also reviewed OVSJG performance 

measures and performance documents that the OVSJG used to track goals and 

objectives. We further examined OVC solicitations and award documents and 

verified OVSJG compliance with special conditions governing recipient award 

activity. 

Priority Areas Funding Requirement 

VOCA guidelines require that the OVSJG award a minimum of 10 percent of 

the total grant funds to programs that serve victims in each of the four following 

categories: (1) child abuse, (2) domestic abuse, (3) sexual assault, and (4) 

previously underserved. Because VOCA assistance program grants cover a 4-year 

period, state administering agencies may take more than 1 year to distribute funds 

to subrecipients. 

We examined how the OVSJG allocated VOCA subgrants to gauge whether it 

was on track to meet the program’s distribution requirements. For the FY 2013 

award, we found that the OVSJG complied with the 10 percent requirement. The 

FY 2014 and FY 2015 awards will not close until September 2017 and September 

2018 respectively, and the OVSJG still had significant funding available to distribute 

to subrecipients as of May 2016. We found the OVSJG tracked compliance with this 

requirement and had not made any subawards that would prevent it from meeting 

the allocation requirements. At the time of our review, the OVSJG had not yet met 

the required threshold for funding: (1) the child abuse and sexual assault victim 

categories for the 2014 grant, and (2) the child abuse victim category for the 2015 

4 
 

 

 

 

grant. However, considering the remaining time available to make subawards and 

the balances available for making additional subawards, we believe that the OVSJG 

is positioned to comply with VOCA distribution requirements for both the 2014 and 

2015 grants. 

Annual Performance Reports 

Each state administering agency must annually report to OVC on activity 

funded by any VOCA awards active during the fiscal year.6

 These reports include 

the number of: (1) agencies funded, (2) VOCA subawards, (3) victims served, and 

(4) victim services funded by VOCA assistance program grants. 

The OVSJG submitted annual performance reports to the OVC for FYs 2013, 

2014, and 2015. We discussed with OVSJG officials how they compiled 

performance report data from their subrecipients. An OVSJG official stated that 

subrecipients must provide to the OVSJG quarterly subaward performance data. In 

addition, the OVSJG official explained that during the September and October 

timeframe, the OVSJG provides its subrecipients with an annual performance report 

template to input direct service activity for the entire grant year. The subrecipient 

also returns a completed version of this annual performance report to the OVSJG. 

The OVSJG then compares this annual data to the quarterly information each 

subrecipient previously reported. Once the OVSJG determines the annual 

subrecipient performance data is reliable, the OVSJG uses these reports to compile 

its consolidated annual performance report for the OVC. 

To determine whether the annual performance reports submitted by the 

OVSJG accurately reflected the activity of the grants, we reviewed the most recent 

available Annual Performance Report, covering the period of October 1, 2014 

through September 30, 2015. Table 2 presents summary data from this annual 

performance report. 

Table 2 

Summary from OVSJG’s Annual Performance Report 

FY 2015 

Performance Categories Data Reported 

Number of Victims Served 2,004 

Number of Services Provided 4,988 

Source: OVSJG Performance Report to OVC 

To validate the accuracy of OVSJG’s reported performance data, we 

reconciled OVSJG-reported data to data reported by its subrecipients. We noted 

some instances where the OVSJG inadvertently omitted some subrecipient figures; 

6

 We learned that as of FY 2016, the OVC began requiring state administering agencies to 

submit performance data through a web-based Performance Measurement Tool (PMT). With this new 

system, states may provide subrecipients direct access to report quarterly data for state review. 

5 
 

 

 

 

however, we concluded that any discrepancies resulted in underreported figures to 

OVC. 

Compliance with Special Conditions 

The special conditions of a federal grant award establish specific grant 

recipient requirements. We reviewed the special conditions for each VOCA 

assistance program grant and identified two that we deemed significant to grant 

performance. The first special condition requires that the OVSJG ensure that all 

non-profit subrecipients of VOCA assistance funding make their financial statements 

publicly available. We found that OVSJG subrecipients complied with this 

requirement. The second special condition requires that each VOCA recipient 

submit a Subgrant Award Report (SAR) for each award that details how it intends to 

distribute funds among subrecipients. We found that OVSJG submitted a SAR for 

each of the grant years in the scope of our audit. 

We believe that the OVSJG: (1) is on track to fulfill the distribution 

requirements to priority victim groups, (2) implemented adequate procedures to 

compile annual performance reports, and (3) complied with tested special 

conditions of VOCA assistance program grants. 

Grant Financial Management 

The OJP and DOJ Financial Guides require that award recipients establish and 

maintain an adequate accounting system and financial records that accurately 

account for awarded funds. To assess OVSJG’s financial management of the VOCA 

grants, we reviewed the Washington, D.C., Single Audit Reports for FYs 2013 to 

2015 and identified no significant deficiencies or material weaknesses specifically 

related to the OVSJG. We also interviewed personnel at both the OVSJG and the 

Washington, D.C., Office of Chief Financial Officer (OCFO) who were responsible for 

financial aspects of the grants, reviewed OVSJG’s written policies and procedures, 

inspected award documents, and reviewed financial records. 

Drawdowns 

OJP provides recipients access to an electronic financial management system 

by which grantees must request awarded funds via 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. During our audit, Washington, D.C., OCFO officials 

stated that they drew down VOCA funds on a reimbursement basis. As of March 

2016, the OVSJG drew down $2,416,218 in VOCA funds. To assess whether the 

OVSJG properly drew down these funds, we compared the drawdowns for each 

award through March 2016 to the expenses recorded for each award in the OVSJG’s 

general ledger. This comparison confirmed that the OVSJG properly received VOCA 

funding on a reimbursement basis. 

6 
 

 

Expenditures 

An allowable expense must be reasonable, properly allocated, and 

adequately supported. It also must comply with applicable policies and procedures. 

State administering agency VOCA expenses fall into two overarching categories: 

(1) administrative expenses and (2) reimbursements to subrecipients – which 

constitute the vast majority of total expenses. Table 3 details the administrative 

and subrecipient expenses that the OVSJG charged to the audited grants as of 

February 2016. 

Table 3 

Grant Expenditures
 

Award Number 

Expenditures 

OVSJG 

Administrative 

Expenses ($) 

Subrecipient 

Expenses ($) Total 

2013-VA-GX-0039 59,420 1,047,221 $1,106,641 

2014-VA-GX-0025 65,625 455,087 $520,712 

2015-VA-GX-0047 32,502 756,363 $788,865 

Source: OVSJG’s accounting system – recorded expenses as of February 2016 

Administrative Expenditures 

Under the VOCA authorizing statute, a state administering agency may retain 

up to 5 percent of each grant to pay for training and administering its crime victim 

assistance program. However, such costs must derive from efforts to expand or 

improve how the agency administers the VOCA grant program specifically.7 

Based on the administrative costs the OVSJG charged to the FY 2013 award, 

we determined that the OVSJG complied with the 5-percent limit on grant funds 

used for administrative purposes.8 

We also tested a judgmental sample of 16 administrative cost transactions 

from the three awards to determine whether costs claimed were reasonable, 

supported, and in accordance with the VOCA guidelines. Based on OVSJG’s 

accounting records as of February 2016, the OVSJG incurred expenses in the 

following administrative categories: (1) personnel, (2) fringe benefits, (3) supplies 

and materials, and (4) other services and charges. 

7

 OJP officials emphasized to us that administrative costs charged to a VOCA award must be 

specifically for the VOCA grant program and not for a program supported by other federal or local 

grants – even if such programs assist crime victims. OJP officials further indicated that if a state 

administering agency applies a grant’s administrative funds to cover other office costs, the costs must 

be pro-rated according to the portion used in direct support of VOCA programs. 

8

 Of the three awards within our scope, the OVSJG had drawn down 86 percent of its FY 2013 

award, whereas it had drawn down less than half of the FY 2014 and FY 2015 awards respectively at 

the time of our audit. 

7 
 

 

 

Grantees must charge salaries and fringe benefits to federal awards based on 

records that accurately reflect the actual work performed on a particular award. 

The OJP and DOJ Financial Guides require that grant recipients support payroll 

charges with actual time and effort reports, such as timesheets. Whenever a grant 

recipient works on multiple grant programs or activities, it must apply a reasonable 

allocation of costs to each activity.9 Furthermore, OMB guidance indicates that a 

grant recipient may rely on budget estimates or other distribution percentages 

determined for preliminary or interim accounting purposes, but such estimates 

cannot be used to support charges to federal awards without reconciling after-thefact charges. Ultimately, grantees must ensure that the final amount charged to 

the federal award is accurate, allowable, and properly allocated – based on actual 

time worked. 

The OVSJG used a portion of the administrative funding it retained to support 

the payroll expense of one grant manager specialist employed full-time with the 

OVSJG. The grant manager specialist was the only employee who worked on the 

VOCA assistance program grants until January 2016.10 While our testing confirmed 

that this employee worked on these grants during the audited pay periods, this 

employee was also responsible for working on other Washington, D.C., local grants 

during FYs 2013 through 2016. 

To validate how the OVSJG charged personnel costs to the grants, we 

judgmentally selected for testing payroll and fringe benefit costs associated with 

five non-consecutive pay periods: July 2014, June 2015, July 2015, September 

2015, and February 2016. We examined timesheets and payroll distribution 

records, and found that the OVSJG charged payroll costs to the grant based on 

budgeted rather than actual amounts. We reviewed OVSJG policies for timekeeping 

and charging salary and benefits costs to the grants. While OVSJG policies required 

employees to prepare manual timesheets indicating the time worked on each 

project, we found that these records were based on budgetary information instead 

of the employee's actual time spent on the projects. 

The OVSJG charged its VOCA assistance program grants $129,518 in salary 

costs by using a salary projection spreadsheet created at the beginning of each 

fiscal year. In addition, OVSJG officials stated that the organization’s payroll 

tracking system uses budgetary data, entered as projections, to allocate personnel 

costs to the VOCA assistance program grants.11 Therefore, the OVSJG did not 

allocate final payroll charges to the grants based on actual time. 

Because the OVSJG did not track actual personnel time spent specifically on 

the VOCA assistance program grants as opposed to other non-VOCA OVSJG work, 

9

 The VOCA guidelines also affirm that grantees should document the portion of the time 

spent on the VOCA assistance program using regular time and attendance records. 

10 The OVSJG later assigned an additional staff member to work on VOCA assistance program 

grants, but, as of February 2016, the OVSJG had not used grant funds to pay for this individual’s 

work. 

11 The OVSJG utilizes PeopleSoft as its payroll tracking system. 

8 
 

 

 

the salary expenses that the OVSJG charged to the grants remain unsupported. 

Therefore, we question the $129,518 in salary costs and recommend that OJP 

remedy these costs. We also recommend that OJP work with the OVSJG to 

implement procedures to ensure that it only charges personnel costs to VOCA 

assistance program grants based on actual time and effort reports. 

The OVSJG also incurred costs associated with providing the employee who 

works on the grants fringe benefits that included payroll taxes (Social Security and 

Medicare); health, dental, and vision insurance; and retirement compensation. The 

OVSJG charged $23,289 in fringe benefits to the VOCA assistance program grants. 

Because the OVSJG procedures for calculating the fringe benefit amount charged to 

the grant depended on the projected salary amounts questioned above, we also 

question $23,289 in fringe benefit costs. Therefore, we recommend OJP remedy 

$23,289 in unsupported fringe benefit costs. 

Considering that the VOCA guidelines require that administrative costs 

directly support the VOCA assistance program grant initiative, we also tested five 

non-payroll administrative expenses totaling $6,360 and one $2,500 credit 

pertaining to administrative transactions. The OVSJG classified these six 

transactions as Travel, Supplies and Materials, and Other Services and Charges. In 

general, recipients of DOJ funding must be able to track the use of these funds 

specifically in support of grant activities. A state administering agency should only 

use VOCA funds to purchase equipment and supplies that directly relate to the 

managing of the VOCA grants. 

The OVSJG purchased two desktop computers for two employees with 

administrative funds from its 2014 VOCA award. The OVSJG categorized these 

computers as supplies and materials. The OVSJG purchased these computers in 

September 2015, when only one of its employees worked on VOCA assistance 

program activities. We found that the employee who used the second computer did 

not actually begin working on the VOCA program until February 2016. OVSJG 

officials stated that they believed that they could use VOCA administrative funds to 

support any aspect of teams generally working on victim services and not just on 

costs specifically for VOCA grants or VOCA-assigned staff. 

We find this to be an overly broad interpretation of the allowable uses of 

VOCA funding, particularly given the OVC’s opinion that VOCA administrative funds 

should only be used to support VOCA grant programs. While we consider the 

portion of costs associated with the computers to be immaterial, the OVSJG’s use of 

VOCA funds did not comply with federal grant guidelines for a period of several 

months. 

We also reviewed a $2,000 intra-district advance paid by the OVSJG to the 

Washington, D.C., Executive Office of the Mayor (EOM) for centralized support 

services.12 The OVSJG used VOCA administrative funds from the 2013 grant to 

12 The Washington, D.C., OCFO classifies the intra-district advance as Other Charges and 

Services in its general ledger. 

9 
 

 

 

support an established Memorandum of Understanding (MOU) between the OVSJG 

and the EOM. The centralized support provided by the EOM included shared 

courier, transportation, and telecommunications services. When we inquired how 

this expense supported VOCA-specific grant activities, OVSJG officials stated that 

they used VOCA funding to cover the MOU fee that year because the OVSJG did not 

have sufficient local funding to meet the administration costs in FY 2014. OVSJG 

personnel stated that a portion of these services did directly support VOCA grants; 

however, when we attempted to determine the precise amount, we found that 

neither the OVSJG nor the EOM tracked such shared service activities to any VOCAspecific programs. We concluded that the OVSJG should have pro-rated any 

shared-service contributions only to activities that directly supported VOCA grant 

activities. 

We did not ultimately question the cost tied to the shared services MOU 

contribution described above because an OVSJG accounting error resulted in a 

credit that eliminated the charge to the VOCA grants. We did not identify any 

notable issues with the other administrative cost transactions selected for testing. 

However, in both the instance of the MOU advance and that of the computer used 

by a non-VOCA employee, we found that the OVSJG did not use its VOCA 

administrative funding solely for activities that directly related to administering and 

managing its VOCA assistance grant program. Therefore, we recommend that OJP 

ensure that the OVSJG implements procedures requiring administrative expenses 

paid with VOCA assistance program grant funds be used for activities that directly 

relate to managing VOCA grants. 

Subrecipient Expenditures 

From October 2014 to February 2016, the OVSJG reimbursed eight different 

OVSJG subrecipients $2,258,671 with VOCA assistance program funds. To 

determine the allowability of these subrecipient costs, we judgmentally selected one 

monthly or quarterly reimbursable request package associated with each 

subrecipient. Considering that each subrecipient requested reimbursement for up 

to dozens of separate transactions at a time, we tested 45 subrecipient transactions 

totaling $259,589. The transactions reviewed included costs in the following 

categories: (1) personnel, (2) fringe, (3) travel, (4) contracts/consultants, 

(5) supplies, (6) equipment, (7) training and (8) operating costs. For each 

transaction, we reviewed receipts, accounting records, and associated documents. 

In most instances, we found that subrecipients properly prepared their respective 

reimbursable request package and that the OVSJG properly billed subrecipient 

expenses to the 2013, 2014, and 2015 awards. 

We found one subrecipient used an unallowable method to calculate the 

health benefits it charged to the VOCA program. This subrecipient provided its 

employees with a set health insurance allowance and did not request support for 

the actual health expenses that the employees incurred. In the budget that this 

subrecipient prepared for the OVSJG, the subrecipient noted it would make charges 

to the health insurance cost category, but it did not elaborate on the methodology it 

would use. Our sample included health allowances for two employees in one 

quarter, totaling $1,500. OJP’s Office of the Chief Financial Officer confirmed that 

10
 
 

 

 

structuring the benefit in this way was unallowable. We therefore question these 

costs as unallowable and recommend that OJP work with the OVSJG to remedy the 

$1,500 in unallowable subrecipient health allowance costs. We also recommend 

that OJP work with the OVSJG to ensure that it only approves reimbursement of 

health benefit costs based on actual employee health benefit expenses. 

Matching Costs 

VOCA guidelines require that subrecipients match 20 percent of each 

subaward to increase the amount of resources to VOCA projects, which will prompt 

VOCA subrecipients to obtain independent funding sources to help ensure future 

sustainability. Although subrecipients must derive required matching contributions 

from non-federal, non-VOCA sources, subrecipients can provide either cash or an 

in-kind match to meet matching requirements.13 VOCA guidelines state that any 

deviation from this policy requires OVC approval. 

We reviewed OVSJG Requests for Application (RFA) announced to potential 

subrecipients each year. In 2013, the OVSJG accurately detailed VOCA matching 

requirements to prospective subrecipients per VOCA guidelines. However, in 2014 

and 2015, the OVSJG announced that it would provide the required 20-percent 

match for prospective subrecipients. When we inquired about this interpretation of 

the match requirement, OVSJG officials stated that subrecipients previously 

reported that they struggled to provide and account for it. Therefore, the OVSJG 

decided to take over the responsibility of providing the VOCA match requirement for 

its subrecipients for its FY 2014 and subsequent awards. 

Specifically, OVSJG personnel told us that they believed they could meet 

subrecipient match requirements by funding local grants for services similar to the 

purposes of VOCA assistance program grants. However, we found that this 

approach did not align with the match-requirement goal of increasing overall 

resources supporting VOCA projects. Moreover, according to OJP officials, a state 

administering agency should report to the OVC whenever one of its subrecipients 

cannot match 20 percent of its VOCA subaward and request that the OVC waive its 

subrecipient’s matching amount requirement. Further, if a state administering 

agency were to take over the match responsibility for the subrecipients, OVC 

officials added that they would want OVC to be notified. We conclude that although 

the OVSJG could potentially match costs without violating the VOCA guidelines, it 

still should have proactively sought OVC approval for handling the match at the 

13 For the VOCA assistance program, in-kind matches may include donations of expendable 

equipment, office supplies, workshop or classroom materials, workspace, or the value of time 

contributed by those providing integral services to the funded project. 

11
 
 

 

 

 

 

state administering agency level or an OVC waiver of the VOCA subrecipient match 

requirements.14 

In our opinion, the OVSJG’s interpretation of the VOCA match requirement 

did not enhance the VOCA assistance program as intended by the VOCA 

guidelines. Further, OVSJG reports of subrecipient matches did not accurately 

reflect its approach to this requirement. Therefore, we recommend that OJP ensure 

that the OVSJG adjusts its procedures to comply with VOCA matching 

requirements. We further recommend that OJP require that the OVSJG institute 

procedures to ensure that it accurately reports VOCA subrecipient matching 

amounts or otherwise seeks from the OVC a waiver whenever a subrecipient cannot 

meet the VOCA matching requirement. 

Financial Reporting 

State administering agencies must report to OJP all expenditures via a 

Federal Financial Report (FFR) no later than 30 days after the last day of each 

quarter. To determine whether the OVSJG submitted accurate federal financial 

reports, we compared four OVSJG FFRs for the 2013, 2014, and 2015 awards to 

expenditures recorded in OVSJG accounting records. This review found that the 

FFRs accurately reflected the expenditures recorded in OVSJG accounting records. 

In our overall analysis of the OVSJG’s grant financial management, we found 

that the OVSJG had an adequate system in place to record and report on the 

receipt, obligation, and expenditure of grant funds. In addition, our assessment 

found that the OVSJG has generally maintained adequate controls over the financial 

management system used to administer grant funds. However, we identified 

specific weaknesses related to the OVSJG’s use of its administrative portion of grant 

funds permitted from these grants, specifically its payroll procedures. We also 

identified issues with the OVSJG’s handling of the matching funds requirement and 

one subrecipient that made unallowable grant charges within our sample. 

Monitoring of Subrecipients 

According to the OJP and DOJ Financial Guides, the purpose of subrecipient 

monitoring is to ensure that subrecipients: (1) use grant funds for authorized 

purposes, (2) comply with the federal program and grant requirements, laws, and 

regulations, and (3) achieve subaward performance goals. As the primary grant 

recipient, the OVSJG must develop policies and procedures to monitor its 

subrecipients. To assess how well the OVSJG monitored its VOCA subrecipients, we 

interviewed OVSJG and subrecipient personnel, identified OVSJG monitoring 

procedures, and obtained records of interactions between the OVSJG and its 

subrecipients. 

14 As previously noted, each state administering agency must submit a Subgrant Award 

Report (SAR) to the OVC that details subrecipient match contributions. For the grants under audit, 

the OVSJG reported in its SARs that subrecipients matched 25 percent of VOCA funds even though the 

subrecipients did not directly contribute funds to meet the match requirement. OVSJG officials agreed 

that these subrecipient match amounts were not accurate. 

12
 
 

 

The OVSJG’s grant manager specialist is responsible for monitoring the 

subawards to ensure compliance with federal and District laws, program 

regulations, and administrative requirements, as well as specific subaward terms 

and conditions. OVSJG policies and procedures also require that it hold training and 

orientations with subrecipients on topics such as special conditions, VOCA-specific 

requirements, allowable and unallowable costs, reporting requirements, and other 

financial and programmatic requirements. We confirmed the OVSJG hosted inperson post-award trainings for its VOCA subrecipients in 2013, 2014, and 2015. 

According to OVSJG policy, its grant monitoring also includes periodic site 

visits to the subrecipients.15 However, we found that the OVSJG has not conducted 

a formal site visit for any of the eight VOCA subrecipients under review. While we 

found at the start of our audit that the OVSJG had scheduled formal site visits in 

2016, the OVSJG advised it had put them on hold until the conclusion of this audit. 

Despite the lack of formal site visits, we found that the OVSJG took a multi-faceted 

approach to subaward monitoring and frequently communicated with its 

subrecipients. Further, during the audit, the OVSJG updated its policies to outline a 

new process for assigning risk designations to subrecipients and stipulated that 

high-risk grantees may receive site visits once a year or more frequently as 

required. 

Financial Monitoring 

As required by VOCA award special conditions, the OVSJG ensures that all 

prospective subrecipients submit financial information, such as financial statements, 

as part of their applications for subawards. The OVSJG also requires as part of its 

subrecipient application process that potential applicants submit proposed budgets. 

Further, the OVSJG grant manager specialist must review and approve any financial 

changes affecting a subaward. 

The OVSJG requires its subrecipients to complete and submit a 

reimbursement request worksheet, which details expenses by cost category for a 

monthly or quarterly reporting period. Subrecipients must also upload supporting 

documents, such as receipts and proof of payment, for these reported expenses. 

The OVSJG grant manager specialist then compares the reimbursement request to 

the supporting documents to ensure that the amounts both reconcile to the 

expenses claimed and are allowable based on the subrecipient budget. If the grant 

manager specialist finds that all costs claimed were allowable and reconcile, the 

grant manager specialist approves the reimbursement request for payment. We 

found that the OVSJG had comprehensive records on its subrecipient expenses and 

activities. Additionally, we noted evidence of OVSJG personnel initiating and 

responding to questions regarding consultant rates and rental agreements. 

15 OVSJG personnel said that during site visits they would perform interviews, request support 

for expenses claimed, and subsequently describe any compliance issues, findings, or risk designations 

they deemed applicable. 

13
 
 

 

 

 

 

 

In addition, we evaluated the OVSJG’s monitoring of the single audit 

requirement for its subrecipients.16 We found the OVSJG requires its subrecipients 

submit all single audits and corrective plans for review to verify if any material 

issues require follow-up by the OVSJG. The OVSJG grant manager specialist did 

not note any concerns with material issues affecting the VOCA grants. To test 

OVSJG’s single audit monitoring process, we requested the financial statements for 

the eight subrecipients, and found two subrecipients met the threshold of federal 

expenditures totaling $750,000 or more in FY 2015. We confirmed these 

subrecipients had single audits completed and submitted the reports to the OVSJG. 

We reviewed the single audit reports and corrective action plans and did not note 

any unaddressed material findings affecting VOCA subawards. 

Performance Monitoring 

OVSJG officials stated that the grant manager specialist monitors 

subrecipient performance to validate reported accomplishments and evaluate VOCA 

program effectiveness. The OVSJG requires that subaward applicants detail goals 

and objectives for their proposed programs. If selected to receive an award, 

subrecipients must submit quarterly summaries of their activity in support of each 

goal and objective. Subrecipients elaborate on the details of this activity in 

quarterly narratives, which include descriptions of factors that facilitated or 

impeded successful implementation of projected goals, as well as future planned 

activity. The OVSJG also collects quantitative performance data from its 

subrecipients on a quarterly basis. The OVSJG grant manager specialist compares 

this data to each subrecipient’s projected performance figures in order to verify that 

the subrecipient is reasonably on track to meet its stated goals and objectives. 

Additionally, OVSJG officials told us that on a semi-annual basis they request 

support for select subrecipient performance figures to validate their reported data. 

In FY 2016, the OVSJG also began identifying outcome measures to 

document the impact of work by VOCA subrecipients in their communities. These 

measures are specific to the type of service provided and range from qualitative 

observations on an individual’s willingness to engage in mental health services to 

placement details for individuals leaving shelters. The OVSJG is encouraging its 

subrecipients to report on such measures so it can better capture the results of its 

VOCA subrecipient efforts. 

While reviewing how the OVSJG compiled performance data from its 

subrecipients to prepare Annual Performance Reports, we also assessed 

subrecipient performance reports. We sought support for select subrecipientreported figures and visited two OVSJG subrecipients to confirm the number of 

victims reported as served by VOCA funding. 

16 As of December 2014, a non-federal entity that expends $750,000 or more in federal 

awards during the entity's fiscal year must have a single audit conducted. The Single Audit Act 

Amendments of 1996 and CFR Part 200.100 (d) define a single audit as an audit of a non-federal 

entity that includes the entity’s financial statements and federal awards. 

14
 
 

 

 

 

 

 

 

	 The first subrecipient provided client intake entries to support how many 

victims of assault, stalking, and domestic violence it served. This 

subrecipient also used an effort-to-outcome system to track demographic 

information, type of victimization, intake date, and other relevant information 

data, as well as the results of client needs assessments. 

	 The second subrecipient manually recorded client data and subsequently 

entered the information into a client services tracking system. This 

subrecipient used both paper files and its tracking system to store client 

records needed to report performance data to the OVSJG. This subrecipient 

generated an electronic report and produced hard copies to support the 

number of child sexual abuse and domestic violence victims it served. 

The OVSJG’s methods of monitoring include: (1) frequent communication, 

(2) face-to-face meetings, (3) quarterly programmatic reports, (4) financial status 

reports and payments requests, and (5) other technical assistance as needed. Our 

interviews with two VOCA assistance subrecipients corroborated that the OVSJG’s 

grant manager specialist is available for day-to-day interactions with the 

subrecipients and discusses any issues or concerns with subrecipients regularly. 

Consequently, we believe that the OVSJG has implemented subrecipient monitoring 

efforts that provide reasonable assurance that its subrecipients comply with the 

terms and conditions of VOCA awards. 

Conclusion 

We found the OVSJG used its grant funds to enhance services for crime 

victims. We did not identify significant issues regarding award annual performance 

reports, drawdowns, federal financial reports, and subrecipient monitoring. 

However, we did identify $154,307 in total dollar-related findings and believe that 

the OVSJG needs to improve its procedures for complying with the match 

requirement and using its administrative funding. We made eight 

recommendations to improve the OVSJG’s management of VOCA awards. 

Recommendations 

We recommend that OJP: 

1. Remedy $129,518 in unsupported salary costs. 

2. Work with the OVSJG to implement procedures to ensure that it only charges 

personnel costs to VOCA assistance program grants based on actual time and 

effort reports. 

3. Remedy $23,289 in unsupported fringe benefit costs. 

4. Ensure that the OVSJG implements procedures requiring administrative 

expenses paid with VOCA assistance program grant funds to be used for 

activities that directly relate to managing VOCA grants. 

15
 
5. Work with the OVSJG to remedy the $1,500 in unallowable subrecipient 

health allowance costs. 

6. Work with the OVSJG to ensure that it only approves reimbursement of 

health benefit costs based on actual employee health benefit expenses. 

7. Ensure that the OVSJG adjusts its procedures to comply with VOCA matching 

requirements. 

8. Require that the OVSJG institute procedures to ensure that it accurately 

reports VOCA subrecipient matching amounts or otherwise seeks from the 

OVC a waiver whenever a subrecipient cannot meet the VOCA matching 

requirement. 

16
 
 

 

 

APPENDIX 1 

OBJECTIVE, SCOPE, AND METHODOLOGY 

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

implemented Washington, D.C.’s crime victim assistance program. To accomplish 

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

(1) victim assistance award planning, (2) program requirements and performance 

reporting, (3) grant financial management, and (4) monitoring of subrecipients. 

We conducted this performance audit in accordance with Generally Accepted 

Government Auditing Standards. Those standards require that we plan and 

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

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

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

conclusions based on our audit objective. 

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

grants 2013-VA-GX-0039, 2014-VA-GX-0025, and 2015-VA-GX-0047 to the District 

of Columbia’s Office of Victim Services and Justice Grants (OVSJG). The Office of 

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

totaling $7,100,587 to the OVSJG, which serves as the state administering agency. 

Each of the awards in our scope has a four-year period of performance, and our 

audit concentrated on, but was not limited to, the period of October 1, 2012, the 

project start date for VOCA assistance grant number 2013-VA-GX-0039, through 

October 2016. 

The authorizing VOCA legislation, the VOCA Assistance Final Program 

Guidelines, and the OJP and DOJ Financial Guides contain the primary criteria we 

applied during the audit.17 To accomplish our objective, we tested compliance with 

what we consider to be the most important conditions of the OVSJG’s activities 

related to the audited grants. We performed sample-based audit testing for grant 

expenditures including administrative and subrecipient expenses, financial reports, 

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

designed 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. During our audit, we obtained 

information from OJP’s Grants Management System as well as the OVSJG’s 

accounting system specific to the management of DOJ funds during the audit 

period. We did not test the reliability of those systems as a whole; therefore, any 

findings identified involving information from those systems were verified with 

documents from other sources. 

17 The OJP Financial Guide governs the FY 2013 and 2014 grants in our scope, while the 

revised 2015 DOJ Financial Guide applies to the FY 2015 award. The revised DOJ guide reflects 

updates to comply with the Uniform Grant Guidance, 2 C.F.R. part 200. 

17
 
 

APPENDIX 2 

SCHEDULE OF DOLLAR-RELATED FINDINGS 

QUESTIONED COSTS18 AMOUNT($) PAGE 

Unallowable Costs 

Unallowable Costs – Subrecipient Health Allowance 1,500 10 

Total Unallowable Costs 1,500 

 

Unsupported Costs 

Unsupported Costs – Payroll 129,518 8 

Unsupported Costs – Fringe Benefits 23,289 9 

Total Unsupported Costs 152,807 

 

TOTAL QUESTIONED COSTS $154,307 

18 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, or the provision of supporting documentation. 

18
 
••• """ ex:: 

• • • OVSJG ........ _- ---

APPENDIX 3 

OFFICE OF VICTIM SERVICES AND JUSTICE GRANTS 

RESPONSE TO THE DRAFT AUDIT REPORT 

19
 

GOVUNMENJ OF THE DISTRICT OF COlU ...... IA 

Executive OITk:e 0/ the NoaotDl 

OFACI Of VICTIM !oERVlCES AND JUSTICE GRAHlS 

~S,2017 

John J. MionnncFlqi<>noI AIat Monocer W~on ~A'-OI'fi<:. 

orrx. at "'" 1_ Gen<noI 

us. ~at_io< 

1300 N. 17tI> ser_, -., 3400 

Arlircton. VA 22209 

!!IA'I! 'i. MqjlqadflCOcwjr Mpht· /pl!p M9P1iaQUfI!lY1gj qqr 

Do. Mr. Monnrc: 

_ 0<Cepf thi5 _ .. '-""" to "'" dnfI AUCJrt _ on "'" VKtm ~ f<><m<N 

-

_ .... _ by "'" 0I!i« at _ ~"" IOfn orrx:., far _ at ~ to "'" 

_ at CGunao'. 0I!ice 01 Vdim S<nri<e<.-.I -., ~'" " ,"',." to on iIUdit of pooo, 

numl><r< 201]'-VA-GX-«l3'I, 

p.-. 

2014-VI\-GlI-«I25, ..-.JlOlo;.-VIKilI-«M7. W. _ .... .., "'" 

,-

""""""niIy to 

_1._ 

,"-.-.I _ .1<0 _ to tho'*- "'" __ tHm far .. of_ 

Th< __ «>nUoin<.;ct1t ~ on<! $154,307 .. __ con.. Thi< _ 

_ ~ .. our to "'" _1'iroIinI> ............ «1 "" _10;.-16 at "'" 

L R<metIy 5129.'iI . ..... __ eel .. .., ....... 

L Wofil __ 0V§J6 to i"",,,,,,,, ~e5'0 ....... tho. it only d'Iar __ _ 

""'. to IIOUI ...... once _ .... IT .... _ on Ktuol time _.non ,_ 

"" R<metIy 52l.lII!I" .... _eel frin~ _ rosu. 

Th< 0Ifi<r atYKbm S<nri<e< _ J_ Gnnt>~. <anal" _ ~ I, 2, 

_ 3_ Hq;f ... C Octob« I, 1016, ___ byVOCA .d". __ 1urofI<..., 

"...oO>O-c ......... -.._.-. ____ onVOCA-...:.~m 
1f1llU •• ~I .. octM!'" fUnded by _ """" ... Quanorly, octu.ilimo 'Pffl< will be 

,«onciI_ ,«onciIod ""'" "'" budcotod . .. " ... ", ...-., "'" Di<trict •• -VI'I"(I"oIsymm. TlIi< i< necewf"/" the limMheel/l'I"(I"oIi <Y>1.m don "",no.. "'" <""",,U y 10 

,«on! ICIUII """"..,.." on cront P"0CJI'II5. _I ""m.. wiI be ~ q.IIftorty .. 

_10........, 1l1li 1'1"(1"01 dIorlft-"'ory ond frInto _ •• llIocI1od _ on 

octUli ti"",. 

w. 

= 

wiI willi OJP '" "'" $15U1{)a/ .. Irir"c< _ 

•. 

~ ~ ""5Up!IOI1od 1ory ond 

I. [ " "".11>01 tI .. oyu; ;, .......... nu P<"""""" ,tquifinl: tdfnin;'IUtNe .. _ paid ""'" 

IIOCA ............. _om cr .. ' fIIn"'.o be _ r .. octM6o> "' • • dirfCtIJ.-., to .... nocirc 

IIOCA rr.nn. 

OIISIG ,,,,,,,,,,,wilI>.ho ~.Iion

whO <MOl "'" 

VOCA ....... nu: 

«<_ ~.oMtioos , .... _ 11o •• Of, ... WO ..... IiIc •• O now _'ho purcI">l>t<I witII .. minimo ..... fun4< P<_ """"'"' ."'9Ioyft r .. 

prior'o h ....... portion 01 hcr ~ ,o.,,"lIototcd to 

VOCA _"._fun4<. A<TMtlc< _ ...-"" """"'" to tIl. VOCA _, .... '" 

.......... "'" point of <anloct """" .... VOCA _fltor .... on Ic ......... Kt~ ... 1¥"c 

"'" VOCA _.,Ism,or on .. ....mi .. to <ub-(r .... -. 

GoII"I( _1<1. 

_. 

OIISIG 004II .......... """_ imotprflllion 01_ ..... u"",, ond........,.", 

non-poymIl __ -" dftct!oj 5Up!IOI1 VOCA 11'1'" _ .... . 

. WofIc";'h ,he ~ '" r<rnedy.he $1.500 in unallowoblc wbr«ipicrM ...--...-., 

i. Work";'h 'he ~ t" ......... "'. , ~ or"Iy ."",ova of .... 111> berI<IiI 

<0<1. INOSH on _01 ~ h .. "" 1ioCMIIt...,.,..... 

.cion""'_' 

OIISIG ,oncun will> ,'"""""""",,,., ... ~.ncI 6. In 11"11< in .. _ ••• he IObccipO;n' """""" • 

stipend '0 crr"CIio"/ceo to if oIi.·., 'OIly sctW ..... "" bcn<rfl> .... hiI. fCQUired cmlllo¥ft< '0 

<ifn!II\' 'crtity uSC 01 ,he " .... " is lor.-..-" ~ only. McM"" ........ If".. OIISIG wi. 

, ... b<rsc only octuol __ '0,,, OlJpporIod by cWIcn<e of ICIM: he.hII<or. awerocc 

., "'" Iotm of I pmnium ............ _ me CftIlIIoyH',,,,,o __ • pr-.. 

W. will coor<IifIok wIm OW to ~ me $1,500111 ""_ IObccipO;nl hel"" 

01_<><000<1 •. 

7. Emu" 11>01 .... ~ odium it< pfO.ecI ... e< ,,, comply _ VOCA ..... ch .... ,cqu ............ 

•. A ........ IfIII,.hO OVSJ6 inslinr .. po-O<ecIIr.e< ,,, ........ n .... it ...... ,'" • ....,.... VOCA 

wbrccipO;nl mOleNnc _u Of 0Ihc<wisc oedr.lrom tIl. ove ... ..., ""'-• 

WDrcripien. , ... "'" nIH ...... VOCA ..... <hint ........ """"" 

, 

20
 
OVS!G portiolly rona"" with (Kom"",ndolion, 7 .nd 8. O\I!iIG i> co ...... ittNi to ,",ulire that 

ou( p«><.d ... es ,omply w~h VOCA matdlinc 'oquiremon", that ... occum.1y ,..,.,.., VOCA 

matchinl .....,.,n",'ro!..et. __ lrom CNC., •• NlNI. Ho~', ...... ~ boen Io<.d with 

d1al.,.es in . "....ire odl1efrnc. to th . .. (rqu ........ n" du. to ncomi>t..,t ,.~ ... h ..... 

'r<: .... d hom O'Ie to mot<h ,.IaINI 

w., 

quoshon,_ OVS!G _ it' •• ''''mptioo 01 tho mat,h 

'«IU_", with ~ food, .Uow.~ I>iI....r on ~ disc.,,,,,,,, with CNC stott_ 

Add~ionolPy, _ tho oud~ _, oc,.mrc. OVSJG stott "'o<hNl out to CNC to try ond ,., 

_~ioo.1 ctorificatioo on match ,.IaINI q",,"ioo. _ W<f< ...... i><d that .... omw'''oUd fKlt 

110 1"_ at tho ...... _ 0... uno.maro!ire i> tho< OJP may 110 i>"'ire ""_ l\>iclorlCO 

(rprdire rno<d1 in 1M".., ,., ..... nd ... _'orw.rd to.ny .d_ I\>icla",. to .n""", 

that O'I!;)G i> in fIJI romp/ion<. w~h VOCA matd\irc ",q"""""''' 

Tho OIf"" 01 Victim ~ .... d J."u G~" vory mud! 'PI',«iiI"', t"-' owortooityto 

''''!'OfId to this draft ,"pon. W.loot I""",",d towortinJ: with OJP to """'"" tho 

(Kommef'datioo. in 1M '"port_ H you ... ~."y q""ioo, or ""111ft odditionill inlonnation or 

docum."talion, p . ... con,"" m< at mg' '''' @I'i.Pd,oll\! or102-n4-n16_ 

Sincomy, 

'v".'·~Wi...i-,W\ . 

MOch . ... M. Go<,iiI 

Oir«lor 

[)i>trict 01 Cd.rrtio OITicr 01 Victim s.Mc: •• and ,"stic. Gr .... 

ce: ljndoToyIor 

Aud~ _ R..-iow DiYi>ion 

OITic

0._ 

r 01 Audit, """"""",nt, oro! Mono&.""'"t 

(}If"r 01 "'''icr P"'I""" 

ficurroo 

G","" M.noc; ..... n' S!>r<iillist 

OITicr 01 Victim Sr<vic:es ond J.sticr Gron" 

"'''"Nit! 

ArI''''Y F~ otric., 

OITicr 01 the 0Iir1 Finontiol Officer 

, 

21
 
APPENDIX 4 

22
 

OFFICE OF JUSTICE PROGRAMS 

RESPONSE TO THE DRAFT AUDIT REPORT 

1.1, 13 1111 

MEMORANDUM TO, J ...... J. M""""'g 

~0II0l "'uJi, ~14nog<, 

lI''''ina''''' R..g;....J Ao.!i, orr"" 

~of'h< n~OfGcn<r.oI 

mOM: 

~~~.>A/ 

SUIllECT: ~ "' Ih< 0..0 AoO i, R<p.>rt, "utIl, uj,h< Ofjh uj ,Jw,b _~._ Off"" fo- nc,_ ojC,;_ " " ''' __ GhMU 

,, ~...a.J '0'0. Ujjia <11'1<11", :>< .. 1",. aoJ loa';'" (,,""", 

W",iljn::<'o,," D,C, 

lbi. '""""'""'" .. in .. fONtlC, to yow """,,~ .. .loud LItoc<m ..... n. 2016. tr.=n>ining 

II>< """, _'~ u..~ ou.!i, !<J"'I1 /01 It.: lI''''''i",'''' D,C. Ofli<:e of Victim S<f-,ires.,-.j 

J...oo: Gnnt> ,OVSJG), " '. coosid.. II><~' .. pot! ",>101\00 0J>d "'l'''''. ".-n""" """"""'" of 

oru. ",tion r""" r<""' uff", •. 

The <Inn """'" rontoj .... <ip' """""_b" ... ."., ~""7 "' """sriontd OO"L 'Il>< 

"''''~ 'ina iuh< orr"" of i ""ia: Provr"""" (Olr) IIlalpi> o{th< ", fi ou.!;, "".., n>«Jmm<ndati<JfU. For ,_ of ""' i< ' ..... "",,,,,,mnodoJiom d il<'<1oJ to OJP "'" ... _oJ ;, 

hold ond ... fo lo~-oJ I:>y """ ""I"'fI"'. 

OlP ~ .. ,~ "'" ,o<ommmdo,ion, w, .. i ll eoo«Iim .. ~ith tho OVSJG 10 r<m<dy tile 

Sll9,~ 18 i. Q~.x-. .. Ia!ed to ..u.y <xp<odi ....... Lhioo .. ~'" ,~ to OIP', 

V""""" of Crim< Act (VOC A) 0. .. , N w'n!:<To 201>-V A--GX -0039. ~O 14. V A.(l X -OOl~, 

..... 20IS·\' A-GX-o!)oI7 

I. W ........ m • • 4 ,h., W P M .. k ~ I,b 'M OVSX; ~ h.pl".,", p""" d. rt> 10 •• , . IT 

~. , II • • .,' ' h. ", ........... .. """ I. VOCA . .... , .... p~'" ..... " b . ...... 

" '.01 ,11., o.d <IT ......... rI ~ 

OJP ~ ~·it" Ih< l«omm<tWtiOll. W .... ill coord; .... "ith the OVSJG IO .-in. 

00f')' ~f ~,;""" poll<i« .M )'>to«>;I ...... ';""<Ior<'d on.! i",,*,,,,,,,'ool. '0 ""'''''' thol 

.. 

p:<s< _,od •• ,,-.:I ""'. .. <"'"1!<'-1 '" VOCA 1:f&1II'''-': bascO 00 ",,, .. Iii,,,,, ope!lt by ito cmplo)'<u 

Ii .... .00_ '"""" ~ 

'_fie"", 

 

.J. W. "' .... m .. d ,h .. OJP .... 04,' WJ8' in ...... 1' ...... fri."" b •• eIi,_. OJP...,... .,itb !he IOOOlIllTlClldorioo. W. will coordi"" .. with tho OVSJG '0 reroedy ,be 

S

~ 

2).2&9 ill quo>tiolltd costI, ...... ,0<1 to f""", ben<fit>rosts uoo<iO!<d with w..y..-

ill _dol;"" Number I. Ibol ___ <hor!!e<I to VOCA Groot Number. 

20ll·VA-GX.ool9, 10l4-V A·OX~. oru;! lOU·V A-QX.(lJ.I1. 

.. W • .--...... d tbOl OJP ........ , ... .., .OV~JG ;'01'1 .... .,. ."'"d . .... ""Ioiri. , 

odmJ.i<l ."Mri .. 

.. 

" ..... p ..... ""HI wI,. VOCA _10 ..... P"'~"" ,. .. , 1110"''' ... "oHfor ' hOI di .. <tIy "'''te, . .... ~nl VOCA JnntJ. 

OJP "III""" with lb. """,mrt>ettdo.ion. W. win ~'" "i!h ,be OVSJG '" obUin. 

ropy of"-.in,,, po>Iici<, on.! procedllreO, devdoped ...J iO'lJ'iemmIed, '" ""' ... tIut 

&oininiruoltiv< txpon><s pOid .. jtJt VOCA Victim ~ Pro""" _ , funds. Ott 

onI~ u>«l r..- >C11>'itie<dit<cUy _ 'v """"11"'<1 VOCA .",oolJ. 

5. w. _ ....... d 'b., OJP ... r k witb the OVSJG .. Mtto<iy 51,stlt in "n,_'oble 

..... ,...,Ipimt 1o .. '1h ....... ....,. ....... 

OJP _ ,ith tho recommen.do.tioo. W. wi ll root<Iino .. wilhtbe OVSJG '" r.n><dy tho 

51.500 in q<mtionod """'. m.ted to SIlbrocipient frin!\< b<R<fit> CO<t. tIW. W<n c:/wll"l 

'" VOCA O:roa, Numben 2t.lll-VA--GX-OOl? 2014-V ",·OX-'XI2!I. an<! 

2015--V "'--GX -0047. 

i . W ....... D1I1l .. d lit .. OJp .. ·.r\( ... ith tit. OVSJG to ....... ,l"t i, n~' •• pro .... 

"'I .. b ............. ' . 'b .. lt ~ 1><"<11, _ .. _ .. !tOIuol ... "I.)·" .... hb _fi, .~

OJ ~ <\0'«' wit. tho 1"«<HmI'<'Idotion. We .. ill oooro;no>: _ ,II< OVSJG OJ 

'''I'Y of..-rilte.tl policies&lld proc<d ..... ""'elope<! and iOlplementod, '0 en<l,Ire 

_in. 

tIIo1 health .......... . _ ..... """'d .. "'" .. , .... _10,.-.... w • ....,... ••• ......_.. 

7. W. r..,.,lDDl<D<l , ... O.IJ' .D ..... 'hat lb. OVSJG adJ"'" It> • .-...."'" fa ,o .. ply 

wijb VI.JoC.' maU;"I """'; ....... ... 

OJP _ .... h th< =mmdotiOD. We ...;11_ ..... ",tit tbe OVSJG to obtain. 

OOP1 of ""';_ poU_ and procod""''' .Je.,'elopod.oo i.,plotnentod. to ............... 

"""'I"ionoo ";th VOCA .... tclli~¥ ""tuimn<nf>. 

23
 
.. w. ftCO ..... nd ,h., OJP 1'«1.1", .... , lb. OVSJG WHO ... p ...... d . ..... """u'" ,hat 

~ ._ .... If "po'" 

.............. VOCA ... b .....,;pl ... ' ..... hl.~ .m . . ... o ... ~ .......... -. fro .. 

tII.OVC . ..

,. 

. M . ............ l ub,...",..", .. n •• ' '"«0 , h. VOCA ... tdH"fI 

OlP _ .. i'h 11 •• """'~ W ... ill .-ioaIo with ,lie OVS.JG 10 obWn. 

oopy of"';,. ... policies or>;! pr«:oo""",. <Ie>doped and ;'npJem •• ted. 10 """"" th3C 

VOCA >Ub«cipi"'" matc~ 1tIIIO<J1U .... o«gntoly 

._

r<poIt«l; ,;pi<mt""""" ODd ..-o.i><n II!< r<q_ 

&un. Q)P', Offi« fu< Vi"' .... ofCri_ ~.,. .....t its VCICA 

'''hioi! "",~. 

W. _;"'0 the ~ 10 ",ie..,.,od = <0 , ... dtoll.w;, '9""'. If,.... hov<: ooy 

«II<Otio .. Of ~ oddiIiOllol ouormllli"" pi ..... oomoct.lcff<l)" A. HaI<y. Dqnrty Diroctor. 

Audit oru:I Revi<w Div;ro., OIl (202) 616-2916 

c," M:rur<o<nA.lle_1><rs 

l'I<puty A~ A1IQm<y GoncnI 

Ii>< Op<ntioos tnd M.~ 

Oft.,. S..uo. ~-A.tv;"" oft ... AWtam Att<n<)' G<onen.I 

AlIDa MortiIl<Z 

Senio< Policy Adv .... 

Off.,. oftlle A3Si<Ion. AtI<rn<y Gooml 

Mfuy A. flaloy 

Deputy DirecIOt, Audit ood R<Yie:w o;viilin. 

Offi", 

.. 

of Awi •. "',..,..mrot,..J MODOg<ID<lI' 

"' Marilyn Robert> 

OfflCt h ~ V;.,tirn$ ofCtihlo 

AUi"", Tutirel 

O/f""", h Vi<tim> of en ... 

~otM","p= 

"'coin£ 

-'""'" 

0.1"") Di_", 

om" '" Vi<ti"" oferi .. , 

24
 
 

0< : J...,.. Simoooon 

AlOO<iat< Di""t<J< fm ()p;ca;""" 

Offoe< fur Vi<U:m ofCrimo: 

T ... n..... .. AlSO<i"", Din<1Of, ~!ate Compensation""; ~ DiviIDl 

Off"", fur Viaim. ofCri.", 

DeLaooFo_ 

Toa .. l<od, St"t, C"""""""ion .... Aui,tHe< Di..woo 

0I!l0t for Viotimo of Crime 

Chorl .. E. M,"", 

DeJuy Gm.noI CO<DI<I 

--

SilasV. ()vdot1 

~ 

Off.,. ofOJrnmunia.tiono 

Chief F......,i. 1 Oft,,,,,,, 

CIo-i>lallokN.il.Wrip! 

.... -'at< Cllitl fm.nciol Off", ... 

anm" Financial M01lIl:"ment Divi<ion 

Ollloe uribe CIti,[flnm:ial Officer 

_ M. SuItingIo. 

A...,.,;.u CIoitl Fi.onci.oI om.,.". f~ ~tloi!. ond AnoI)'Ois DilWoo 

O/Ii"" <of"", Clo1ofFi-.;.1 Off" .... 

Jelry COIll1 

AMisuw Chi<fFi~ 0fIi<e< 

o...u Financial ~t Divioioo 

Offt", of!he CbitlFirw>cioI 0Hic<0 

AI .. ~ 

Aooim.tII Chi<fFi.-ci.ol 0IlI<er 

Fm..".. AoCOllnlina. IIIld AmI.nl> Di,;';on 

oa", of"', ChitlFn-.i.ol Offi= 

• 

25
 
e,,, Aida_ 

MaoooI<t, halo""ioo oM OvetsJji:hI B~ 

(1<_ fim<l<ial MooailoITll:", Di.i""" 

Oftie< of !be Chi.fFiOOf'lCial OffJC ... 

OlP Ext<uti,. s.cmu;", 

Cor-oro! Numl>a M'W1612161Ol!24 

, 

26
 
 

 

APPENDIX 5 

OFFICE OF THE INSPECTOR GENERAL
 

ANALYSIS AND SUMMARY OF ACTIONS 

NECESSARY TO CLOSE THE REPORT
 

The Office of the Inspector General (OIG) provided a draft of this audit report 

to the Office of Victim Services and Justice Grants (OVSJG) and the Office of Justice 

Programs (OJP) for review and comment. OVSJG’s response is incorporated in 

Appendix 3, and OJP’s response is incorporated in Appendix 4 of this final report. 

In response to our draft audit report, OJP concurred with 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. 

Recommendation for OJP: 

1. Remedy $129,518 in unsupported salary costs. 

Resolved. OJP concurred with our recommendation. OJP stated in its 

response that it would coordinate with the OVSJG to remedy the $129,518 in 

questioned salary costs tied to this recommendation. 

The OVSJG concurred with our recommendation and stated in its response 

that it will coordinate with OJP to remedy these costs. 

This recommendation can be closed when we receive evidence that OJP has 

remedied these costs. 

2. Work with the OVSJG to implement procedures to ensure that it only 

charges personnel costs to VOCA assistance program grants based 

on actual time and effort reports. 

Resolved. OJP concurred with our recommendation. OJP stated in its 

response that it would coordinate with the OVSJG to obtain a copy of written 

policies and procedures, developed and implemented, to ensure that 

personnel costs charged to VOCA grants are based on actual time, as 

documented in time and effort reports. 

The OVSJG concurred with our recommendation and stated that staff 

supported by VOCA administrative funds will maintain manual timesheets 

that reflect the actual time spent on VOCA assistance program grants as well 

as activities funded by other sources. Further, the OVSJG stated that it will 

reconcile actual time spent with the budgeted amounts in its payroll system 

on a quarterly basis and that it will perform journal entries as needed to 

ensure that payroll charges for salary and fringe benefits are allocated based 

on actual time. 

This recommendation can be closed when we receive evidence that the 

OVSJG has (1) developed and implemented policies and procedures to ensure 

27
 
 

 

 

staff paid with VOCA funds maintain manual timesheets that reflect the 

actual time spent on VOCA assistance programs and (2) reconciled its payroll 

system with these records of actual time worked and adjusted its funding 

allocations accordingly. 

3. Remedy $23,289 in unsupported fringe benefit costs. 

Resolved. OJP concurred with our recommendation. OJP stated in its 

response that it would coordinate with the OVSJG to remedy the $23,289 in 

questioned fringe benefit costs associated with the salary costs questioned in 

Recommendation 1. 

The OVSJG concurred with our recommendation and stated it will coordinate 

with OJP to remedy these costs. 

This recommendation can be closed when we receive evidence that OJP has 

remedied these costs. 

4. Ensure that the OVSJG implements procedures requiring 

administrative expenses paid with VOCA assistance program grant 

funds to be used for activities that directly relate to managing VOCA 

grants. 

Resolved. OJP concurred with our recommendation. OJP stated in its 

response that it would coordinate with the OVSJG to obtain a copy of written 

policies and procedures developed and implemented to ensure that 

administrative expenses paid with VOCA victim assistance program grant 

funds are only used for activities related to managing VOCA awards. 

The OVSJG concurred with our recommendation and stated in its response 

that going forward the OVSJG will ensure any non-payroll administrative 

expenses directly support VOCA grant programs. 

This recommendation can be closed when we receive documentation 

demonstrating that the OVSJG has established and implemented written 

policies and procedures to ensure that administrative expenses paid with 

VOCA victim assistance program grant funds are only used for activities 

related to managing VOCA awards. 

5. Work with the OVSJG to remedy $1,500 in unallowable subrecipient 

health allowance costs. 

Resolved. OJP concurred with our recommendation. OJP stated in its 

response that it would coordinate with the OVSJG to remedy the $1,500 in 

questioned costs related to subrecipient charges identified in this 

recommendation. 

The OVSJG concurred with our recommendation and revised its approach to 

reimbursing subrecipient health costs, as described in Recommendation 6. 

The OVSJG stated that it would work with OJP to remedy the $1,500 in 

unallowable subrecipient health allowance costs. 

28
 
 

 

 

This recommendation can be closed when we receive evidence that OJP has 

coordinated with the OVSJG to remedy the $1,500 in unallowable 

subrecipient health allowance costs. 

6. Work with the OVSJG to ensure that it only approves reimbursement 

of health benefit costs based on actual employee health benefit 

expenses. 

Resolved. The OJP concurred with the recommendation. The OJP stated in 

its response that it would coordinate with the OVSJG to obtain a copy of 

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

health benefits expenses are limited to actual employee health benefits 

expenses. 

The OVSJG concurred with our recommendation and stated in its response 

that going forward it would only reimburse its subrecipients for actual health 

benefits costs, as supported by evidence of active healthcare coverage – in 

the form of a premium statement from the employee’s healthcare provider. 

This recommendation can be closed when we receive documentation 

demonstrating that the OVSJG has established and implemented policies and 

procedures to ensure that it only approves and reimburses subrecipients for 

actual health benefits costs. 

7. Ensure that the OVSJG adjusts its procedures to comply with VOCA 

matching requirements. 

Resolved. The OJP concurred with the recommendation. The OJP stated in 

its response that it would coordinate with the OVSJG to obtain a copy of 

written policies and procedures, developed and implemented, to ensure 

OVSJG’s compliance with VOCA matching requirements. 

The OVSJG partially concurred with our recommendation and indicated a 

willingness to comply with the program requirements. The OVSJG stated in 

its response that it attempted to adhere to the requirements and needed 

further clarification from OVC regarding how to comply with the match 

requirements. 

This recommendation can be closed when we receive evidence showing that 

OJP has clarified the match requirements for the OVSJG and that it has 

coordinated OVSJG implementation of procedures resulting in compliance 

with the match requirement. 

8. Require that the OVSJG institute procedures to ensure that it 

accurately reports VOCA subrecipient matching amounts or 

otherwise seeks from the OVC a waiver whenever a subrecipient 

cannot meet the VOCA matching requirement. 

29
 
 

 

 

 

Resolved. OJP concurred with the recommendation. OJP stated in its 

response that it would coordinate with the OVSJG to ensure that the OVSJG 

accurately reports VOCA subrecipient matching amounts. OJP also indicated 

that it would work to ensure waivers are requested from OJP OVC whenever 

a subrecipient cannot meet its VOCA matching requirement. 

The OVSJG partially concurred with our recommendation and indicated a 

willingness to comply with the program requirements. The OVSJG stated in 

its response that it attempted to adhere to the requirements and needed 

further clarification from OVC regarding how to comply with the match 

requirements. 

This recommendation can be closed when: (1) we receive evidence that OJP 

has worked with the OVSJG to achieve accurate OVSJG reporting on the 

match amounts, and (2) OJP demonstrates it has clarified with the OVSJG 

precisely when OJP OVC expects requests to waive the subrecipient match 

requirement. 

30
 
31 

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