REDACTED FOR PUBLIC RELEASE Office of the Inspector General U.S. Department of Justice OVERSIGHT ★ INTEGRITY ★ GUIDANCE Audit of the Office on Violence Against Women Grant Awarded to Life Span, Chicago, Illinois REDACTED FOR PUBLIC RELEASE Redactions were made to the full version of this report for privacy reasons. The redactions are contained only in Appendix 3, Life Span’s response, and are of individuals’ names and identifying pronouns. Audit Division 20-022 January 2020 REDACTED FOR PUBLIC RELEASE Executive Summary Audit of the Office on Violence Against Women Grant Awarded to Life Span, Chicago, Illinois Objectives Audit Results The Department of Justice (DOJ) Office on Violence The purpose of the OVW grant we reviewed was to Against Women (OVW) awarded Life Span a grant provide legal services to victims of domestic and sexual totaling $600,000 for the Legal Assistance to Victims violence in Cook County, Illinois. The project period for (LAV) program. The objectives of this audit were to the grant was from October 2017 through determine whether costs claimed under the grant were September 2020. As of March 31, 2019, Life Span drew allowable, supported, and in accordance with applicable down a cumulative amount of $254,209 for the grant. laws, regulations, guidelines, and terms and conditions Program Goals and Accomplishments – Life Span of the award; and to determine whether the grantee demonstrated progress toward completing award goals demonstrated adequate progress towards achieving and objectives. However, we identified concerns with program goals and objectives. the process Life Span used to track performance Results in Brief metrics. Specifically, the support used for Life Span’s July 1, 2018, through December 31, 2018, progress As a result of our audit, we concluded that Life Span is report did not account for staffing changes and their working to achieve the goals and objectives of the OVW associated effect on tracking performance metrics, which award, but must enhance its process to adequately track impacted our ability to reconcile and verify the and report its performance. We also identified areas of information. improvement in Life Span’s financial management structure and compliance with grant requirements. For Grant Financial Management - We found that instance, Life Span’s policies did not incorporate details although the Deputy Executive Director performed many for certain grant-related procedures, such as completing grant-related tasks, Life Span’s policies and procedures the Federal Financial Reports (FFRs), and did not did not provide adequate details or designate back-up designate back-up personnel to perform essential tasks. personnel for completing these requirements. In addition, we determined that Life Span’s drawdown Grant Expenditures - We found that Life Span charged procedures resulted in advancing $5,150 in grant funds $3,446 in unallowable costs associated with changes in that were not expended within the required timeframe. personnel expenses that were not approved by the We also identified that Life Span charged the grant for OVW, as well as $775 in fringe benefits that were not $4,221 in unallowable costs associated with expenses included in the OVW-approved budget. related to personnel and fringe benefits. Drawdowns - As of January 9, 2019, Life Span had Recommendations drawn down a total of $254,209 in award funds. Life Span’s total expenses at that time totaled $249,059, Our report contains seven recommendations to the which resulted in Life Span receiving $5,150 in advanced OVW. We requested a response to our draft audit report grant funds. Life Span officials attributed this advance from the OVW and Life Span, and their responses are to the misallocation of an expense, which was not appended to this final report in Appendices 3 and 4, identified until after the drawdown occurred. respectively. Our analysis of those responses is included in Appendix 5. Federal Financial Reports - Life Span submitted six FFRs during our review period, but did not accurately report its grant expenses for any given reporting period. In addition, three of six FFRs erroneously duplicated expenses, which resulted in Life Span submitting inaccurate information to the OVW. i AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN GRANT AWARDED TO LIFE SPAN, CHICAGO, ILLINOIS TABLE OF CONTENTS INTRODUCTION ............................................................................................. 1 The Grantee ......................................................................................... 1 OIG Audit Approach .............................................................................. 1 AUDIT RESULTS ............................................................................................. 3 Program Performance and Accomplishments ............................................ 3 Program Goals and Objectives ....................................................... 3 Required Performance Reports ...................................................... 3 Compliance with Special Conditions ................................................ 5 Grant Financial Management .................................................................. 5 Budget Management and Control ............................................................ 6 Grant Expenditures ............................................................................... 6 Salary Costs ................................................................................ 7 Other Personnel Costs .................................................................. 8 Rent ........................................................................................ 8 Drawdowns .......................................................................................... 8 Federal Financial Reports ....................................................................... 9 CONCLUSION AND RECOMMENDATIONS ......................................................... 11 APPENDIX 1: OBJECTIVES, SCOPE, AND METHODOLOGY ................................. 12 APPENDIX 2: SCHEDULE OF DOLLAR-RELATED FINDINGS ................................ 13 APPENDIX 3: LIFE SPAN’S RESPONSE TO THE DRAFT AUDIT REPORT ................ 14 APPENDIX 4: OFFICE ON VIOLENCE AGAINST WOMEN’S RESPONSE TO THE DRAFT AUDIT REPORT ......................................................................... 18 APPENDIX 5: OFFICE OF THE INSPECTOR GENERAL ANALYSIS AND SUMMARY OF ACTIONS NECESSARY TO CLOSE THE AUDIT REPORT ......................... 21 AUDIT OF THE OFFICE ON VIOLENCE AGAINST WOMEN GRANT AWARDED TO LIFE SPAN, CHICAGO, ILLINOIS INTRODUCTION The U.S. Department of Justice (DOJ) Office of the Inspector General (OIG) completed an audit of a grant awarded by the Office on Violence Against Women (OVW), Legal Assistance for Victims (LAV) Program, to Life Span in Chicago, Illinois. Life Span was awarded one grant totaling $600,000, as shown in Table 1. Table 1 Grant Awarded to Life Span Project Project Program Award Award Number Award Date Period Start Period End Office Amount Date Date 2017-WL-AX-0035 OVW 9/22/2017 10/1/2017 9/30/2020 $600,000 Total: $600,000 Source: OJP’s Grants Management System According to the OVW, funding through the LAV Program is intended to increase the availability of civil and criminal legal assistance programs for adult and youth victims of domestic violence, dating violence, sexual assault, and stalking who are seeking relief in legal matters relating to or arising out of that abuse or violence. The Grantee Founded in 1978, Life Span provides services for women and children who are victims of domestic and sexual violence, including legal services, advocacy, and counseling. Life Span’s mission is to empower survivors of domestic and sexual violence to demand safety as a human right through client-centered services and lead social change through accountability, community engagement, and systemic advocacy. OIG Audit Approach The objectives of this audit were to determine whether the grantee demonstrated adequate progress towards achieving the program goals and objectives; and to determine whether costs claimed under the grant were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and terms and conditions of the grant. To accomplish these objectives, we assessed performance in the following areas of grant management: program performance, financial management, expenditures, budget management and control, drawdowns, and Federal Financial Reports (FFRs). 1 We tested compliance with what we consider to be the most important conditions of the grant. The DOJ Grants Financial Guide and the award documents contain the primary criteria we applied during the audit. The results of our analysis are discussed in detail later in this report. Appendix 1 contains additional information on this audit’s objectives, scope, and methodology. The Schedule of Dollar-Related Findings appears in Appendix 2. 2 AUDIT RESULTS Program Performance and Accomplishments We reviewed required performance reports, grant documentation, and interviewed grantee officials to determine whether Life Span demonstrated adequate progress towards achieving the program goals and objectives. We also reviewed the progress reports to determine if the required reports were accurate. Finally, we reviewed Life Span’s compliance with the special conditions identified in the award documentation. Program Goals and Objectives The OVW awarded the LAV Grant Number 2017-WL-AX-0035 to Life Span to provide legal services