Rehabilitation: Recurring Material Internal Control Deficiencies
||First Year Reported
|Rehabilitation Services--Vocational Rehabilitation Grants to States
||During our audit for fiscal year 2011-12, we reported that DOR lacked adequate controls to determine applicant eligibility for services within the required 60-day time period and to develop an IPE within 90 days of eligibility determination. In fiscal year 2012-13, we found DOR continued to lack adequate controls and was not compliant with federal regulations. We tested 65 applicant cases and found the following: • Thirteen cases were not deemed eligible within the 60-day time period. • Four cases did not have an IPE developed within the 90-day time period. • Seventeen cases had application dates in the file that did not agree to the application dates in the AWARE system. DOR relies on the application dates input into the AWARE system as a tracking mechanism to meet the 60-day and 90-day requirements. • Six case files were missing either the Eligibility Determination form (DR 212) or the required signatures on the form. • Four case files were missing either the IPE or the required signatures on the IPE. • One case did not have a signature or date by the applicant or DOR counselor on the application form (DR-222). • Ten cases lacked evidence of a supervisor’s review to confirm that eligibility was properly determined. Failure to determine an applicant’s eligibility and develop an IPE within the required time period prohibits applicants from receiving timely vocational rehabilitation services.
|The Department of Rehabilitation (DOR) agrees with the finding related to determining eligibility within 60-days, developing an Individualized Plan for Employment (IPE) within 90-days, discrepancies between application dates on the Vocational Rehabilitation (VR) Services Application (DR-222) compared to Accessible Web-based Activity Environment (AWARE), missing forms, and requisite signatures. Corrective Action Plan: In accordance with federal regulations, qualified VR counselors have the authority to determine eligibility and approve payments. DOR will strengthen its internal controls through standardized casework reviews of senior counselors with approval authority who determine eligibility and authorize payments to consumers. DOR initiated and implemented a statewide monitoring plan for the 60-day eligibility and 90-day IPE timelines to address the findings from the Fiscal Year 2011-12 audit. The most recent reports indicate that monitoring has been effective in reducing the number of cases with eligibility not determined within 60-days of application and IPEs not developed within 90-days of eligibility determination. DOR Assistant Deputy Director, VR Employment Division, will assume oversight of this process. • District Administrators (DA) and Team Managers (TM) received training on how to generate AWARE reports to identify consumers who have eligibility determinations and IPEs due in the next 30-days. DA implementation began after training was completed on December 3, 2013. TM
training was completed on September 26, 2013 and January 29, 2014.
• DAs and TMs will review regulations and policies regarding requisite forms and signatures with
applicable staff during monthly management team meetings.
• DOR will strengthen controls for the periodic review of casework for rehabilitation counselors with
approval authority. TMs will conduct annual reviews of at least ten percent (10%) of the cases of
a rehabilitation counselor with post-approval authority to ensure compliance with all applicable
regulations. TMs will document the review findings, and per existing policy, take appropriate action
• DOR will develop policy guidance to be released in Rehabilitation Administration Manual Chapter
30 (RAM 30) to include instructions on requisite documentation by DOR for cases where the
application date on the DR 222 does not match the application date in AWARE.
• DOR will revise the AWARE Reference Guide to include instructions on requisite documentation
by DOR for cases where the application date on the DR 222 does not match the application date in