COUNTY OF LOS ANGELESDEPARTMENT OF AUDITOR.CONTROLLER

KENNETH HAHN HALL OF ADMINISTRATION5OO WEST TEMPLE STREET, ROOM 525LOS ANGELES, CALIFORNIA 90012-3873

PHONE: (213)974-8301 FAX: (213) 626-5427

JOHN NAIMOAUDITOR-CONTROLLER

o

November 6,2017

ïo: Supervisor Mark Ridley-Thomas, ChairmanSupervisor Hilda L. SolisSupervisor Sheila KuehlSupervisor Janice HahnSupervisor Kath Barger

FROM: John NaimoAudito ller

SUBJECT COMMUNITY CAREER DEVELOPMENT, INC. A WORKFORCEDEVELOPMENT, AGING AND COMMUNITY SERVICES PROGRAMSPROVIDER - CONTRACT COMPLIANCE REVIEW

We completed a contract compliance review of Community Career Development, lnc.(CCD or Agency), which included a sample of transactions from July 2016 throughFebruary 2017. Workforce Development, Aging and Community Services (WDACS)contracts with CCD to provide Workforce Innovation and Opportunity Act (WIOA), LosAngeles County Youth Jobs (LACYJ), and General Relief Youth Employment Program(GYEP) services. CCD provided the following Program services:

WIOA Adult and Dislocated Worker Programs which assist individuals in obtainingemployment, retaining their jobs, and increasing their earnings by completing acomprehensive employment assessment of the clients, providing career counselingand planning, assisting with job searches and resume preparations, and whennecessary, offeri ng customized occu pational and/or on-the-job tra in ing.

LACYJ Program which provides assessments, paid work experience, and training toyouth and young adults between the ages of 14 to 24 years old from the CaliforniaWork Opportunity and Responsibility to Kíds, Foster, Probation, Homeless, andGeneral Relief Programs, and low-income households.

GYEP which provides subsidized employment to eligible young adults between theages of 18 to 24 years old from the General Relief Opportunities for Work TransitionalAge Youth population, and assists them in transitioning to unsubsidized employment.

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Board of SupervísorsNovember 6,2017Page 2

The purpose of our review was to determine whether CCD appropriatefy accounted forand spent WIOA, LACYJ, and GYEP Programs (WDACS Programs) funds to provide theservices outlined in their County contracts. We also evaluated the Agency's financialrecords, internal controls over cash, revenue, disbursements, payroll, personnel, andfixed assets, and compliance with their County contract and other applicable guidelines.In addition, for a sample of clients, we reviewed documentation to support their eligibilityand that required Program services were provided.

Our review covered three WDACS Programs contracts with CCD, forwhich WDACS paidthe Agency approximately $1.5 million on a cost-reimbursement basis from July 2016through February 2017. CCD provides services to residents of the Second SupervisorialDistrict.

Results Summary

The following information presents the most significant findings and results. SeeAttachment I for the details pertaining to all of the results noted and recommendationsmade in our review.

CCD developed their Cost Allocation Plan using an appropriate cost allocationrnethodology and maíntained personnel files as required. ln addition, CCD properlyrecorded revenue in their financial records and deposited cash receipts into their bankaccount timely.

However, CCD d¡d not always comply with all of their other County contract requirementsFor example, CCD:

lnappropriately charged or allocated $37,541 ($ZA,XO + $11,331) (68%) of the$55,168 ($40,049 + $15,119) in non-payroll and payroll expenditures reviewed to theWDACS Programs during Fiscal Year (FY) 2016-17.

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CCD's attached response índicates they will re-allocate all shared expenditurescharged to the WDACS Programs during FY 2016-17 based on their time study, andwíll work with WDACS fo determine the total amount to be repaid.

Did not always resolve outstanding items on their bank reconciliations for theiroperating and client payroll accounts timely. Specificallv, we noted 32 items, totaling$4,541 that had been outstanding for over six months, dating back to 2015. lnaddition, 13 (41o/o) of the 32 items, totaling $1,760, related to the WIOA and LACYJPrograms.

Board of SupervisorsNovember 6,2017Page 3

CCD's attached response índicates that after our review, they resolved or began theescheatment process for 12 (92%) of the 13 items related to the WDACS Programs.ln addition, CCD's attached response indicates they will continue to follow up on thelast remaining ítem related to the WDACS Programs, and will resolve outstandingitems in a timely manner moving forward.

We noted similar findings ín our prior year's monitoring report issued on April 5,2017. lnaddition, other issues came to our attention that are relatively immaterial for the purposeof inclusion in this section and are presented in detail in Attachment l.

Review of Report

We discussed our report wíth CCD and WDACS. CCD's attached response (Attachmentll) indicates agreement with our findings and recommendations. WDACS will work withCCD to ensure that our recommendations are implemented.

We thank CCD management and staff for their cooperation and assistance during ourreview. If you have any questions please call me, or your staff may contact AgripinoAlonso at (213) 253-0301.

JN:AB:PH:AA:EB:PN

Attachments

c: SachiA. Hamai, Chief Executive OfficerCynthia D. Banks, Director, WDACSWil Bratcher, Board Chair, CCDAlberto Uribe, Executive Director, CCDPublic lnformation OffíceAudit Committee

Attachment I

COMMUNITY CAREER DEVELOPMENT, INC.WORKFORCE DEVELOPMENT, AGING AND COMMUNITY SERVICES PROGRAMS

CONTRACT COMPLIANCE REVIEWJULY 2016 THROUGH FEBRUARY 2017

ELIGIBILITY

Obiective

Determine whether Community Career Development, lnc. (CCD or Agency) maintaineddocumentation to support the eligibility of clients that the Agency claimed receivedWorkforce lnnovation and Opportunity Act (WIOA), Los Angeles County Youth Jobs(LACYJ), and General Relief Youth Employment Program (GYEP) services.

Verification

We reviewed the documentation stored in the case files for 85 (1Ùo/o) of the 816 clientsthat CCD claimed received WIOA, LACYJ, and GYEP Programs (WorkforceDevelopment, Aging and Community Services (WDACS) Programs) services from July2016 through February 2017.

Results

CCD maintained documentation to support the eligibility of the 45 WIOA and GYEPProgram clients reviewed. However, one (3%) of the 40 LACYJ Program clients reviewedwas not eligible to receive LACYJ Program services. Specifically, CCD enrolled a clientwho exceeded the eligible age limit (24 years old) for the LACYJ Program. As a result,CCD inappropriately charged WDACS $953 for the ineligible client's work experiencehours.

Recommendations

Community Career Development, lnc. management:

Review all Los Angeles Gounty Youth Jobs Program expenditures billedto Workforce Development, Aging and Community Services duringFiscal Year 2016-17 to identify any additional expenditures for ineligibleclients charged to the Program, and repay any unallowable amounts.

Repay Workforce Development, Aging and Community Services $gSg.

Ensure that all Los Angeles County Youth Jobs Program clients areeligible to receive Program services as required.

AU DITOR-CONTROLLER

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COUNTY OF TOS AAf GELES

Communitv Career Develooment- lnc- Pase 2

PROGRAM SERVICES

Obiective

Determine whether CCD maintained documentation to support the services charged toWDACS.

Verification

We reviewed the case files for 85 (10o/o) of the 816 clients that the Agency claimedreceived WDACS Programs services from July 2016 through February 2017.

Results

CCD generally maintained documentation to support the services provided to the 85clients reviewed. However, as noted in the Eligibility section of this report, one (3%) ofthe 40 LACYJ Program clients reviewed was not eligible to receive LACYJ Programservices.

Recommendations

Refer to Recommendations I and 3.

CASH/REVENUE

Obiective

Determine whether CCD properly recorded revenue in their financial records, depositedcash receipts into their bank account timely, and if bank reconciliations were preparedtimely, and reviewed and approved by Agency management.

Verification

We interviewed CCD's management, and reviewed their financial records and February2017 bank reconciliations for four bank accounts.

Results

CCD properly recorded revenue in theirfinancial records and deposited cash receipts intotheir bank account timely. However, CCD did not always resolve outstanding items ontheir bank reconciliatíons for their operating and client payroll accounts timely.Specifically, we noted 32 items, totaling $4,541 that had been outstanding for over sixmonths, dating back to 2015. ln addition, 13 (41%) of the 32 items, totalíng $1,760,related to the WIOA and LACYJ Programs. We noted a similar finding in our prior year'smonitoring report issued on April 5,2017.

AU DITOR-CONTROLLERCOUNTY OF LOS AAf GELES

Gommunitv Gareer Development, lnc Pase 3

Recommendations

Community Career Development, lnc. management:

4. Repay Workforce Development, Aging and Gommunity Services $1,760,or provide Workforce Development, Aging and Community Serviceswith supporting documentation.

5. Resolve outstanding items in a timely manner.

COST ALLOCATION PLAN/EXPENDITURES

Obiective

Determine whether CCD developed their Cost Allocation Plan (Plan) using an appropriatecost allocation methodology, and if expenditures charged to the WDACS Programs wereallowable, properly documented, and appropriately allocated.

Verification

We interviewed CCD's personnel, and revíewed their Plan and financial records for tennon-payroll expenditures, totaling $40,049, that the Agency charged to the WDACSPrograms from July 2016 through February 2017.

Results

CCD developed their Plan using an appropriate cost allocation methodology. However,CCD inappropriately charged $26,210 (65%) of the $40,049 in non-payroll expendituresreviewed to the WDACS Programs. Specifically, CCD:

Did not provide documentation to support the rates used to allocate $24,950 in sharednon-payroll expenditures to the WDACS Programs.

lnappropriately charged $1,260 in supportive service expenditures to the WIOAPrograms. Specifically, the Agency charged the WIOA Programs for gas gift cardsthat they did not distribute to WIOA Program clients. ln addition, the Agency indicatedthey could not provide us with the undistributed gift cards because their custodian wasout of the office, which raises concerns regarding the Agency's ability to providesupportive services to WIOA Program clients as required.

Recommendations

Community Gareer Development, lnc. management:

6. Re-allocate all shared expenditures charged to the WorkforceDevelopment; Aging and Community Services Programs during Fiscal

AU DITOR-CONTROLLER

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COUNTY OF LOS ANGEIES

reer Deve lnc.

Year 2016-17, provide Workforce Development, Aging and CommunityServices with supporting documentation, and repay any unallowable orunsupported amounts.

7. RepayWorkforce Development, Aging and Gommunity Services $1,260.

8. Ensure that all expenditures charged to the Workforce Development,Aging and Gommunity Services Programs are allowable, properlydocumented, and appropriately allocated.

Develop and implement policies and procedures to ensure thatsupportive services are available to Workforce lnnovation andOpportunity Act Program clients as required.

FIXED ASSETS AND EQUIPMENT

Obiective

Determine whether CCD's fixed assets and equipment purchased with WDACS Programfunds were used for the appropriate Programs and adequately safeguarded.

Verification

We interviewed CCD's management, and reviewed their fixed assets and equipmentinventory list. We also performed a physical inventory of five items purchased withWDACS Program funds in prior years to verify the items existed and were being used forthe Programs.

Results

CCD used the five items reviewed for the appropriate Programs, and the items wereadequately safeguarded.

Recommendation

None.

ADM I NISTRATIVE COM PLIANCE

Obiective

Determine whetherthe Agencywas in compliance with theirWDACS Programs and otherCou nty contract ad m in istrative req u irements.

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COUNTY OF ¿OS AÍVGELES

Communitv Career Development, Inc Pase 5

Verification

We interviewed CCD's management, reviewed their policies and procedures manuals,and conducted an on-site visit.

Results

CCD complied with their WDACS Programs and other County contract administrativerequirements.

Recommendation

None.

PAYROLL AND PERSONNEL

Obiective

Determine whether CCD maintaíned personnel files as required and charged payrollexpenditures to the WDACS Programs that were allowable, properly documented, andappropriately allocated.

Verification

We interviewed employees, and reviewed the personnel files for the three newemployees. We also compared the payroll expenditures for eight employees and fiveclients, totaling $15,119 for February 2017, to the Agency's payroll records and timereports.

Results

CCD maintained personnel files as required. However, CCD did not providedocumentation to support the rates used to allocate $11,331 (75To) of the $15,119 inshared payroll expenditures to the WDACS Programs. CCD management indicated thatthe rates were based on a time study but they did not maintain any supportingdocumentation.

ln addition, one (2OYo) of the fíve clients reviewed was overpaid due to mathematicalerrors on the client's timecards for each day that the client worked. Although the amountof the overpayment was immaterial, CCD management needs to ensure that hoursreported on client timecards are accurately calculated and clients are appropriately paidfor their actual hours worked.

AU DITOR.CONTROLLERCOUNTY OF ¿OS AA'GELES

Gommunitv Gareer Develooment. lnc. Paoe 6

Recommendations

Refer to Recommendations 6 and 8.

10. Community Career Development, lnc. management ensure hoursreported on client timecards are accurately calculated and clients areappropriately paid for their actual hours worked.

CLOSE.OUT REVIEW

Obiective

Determine whether CCD's Fiscal Year (FY) 2015-16 Close-Out Expenditure Reportsreconciled to their financial records.

Verification

We compared the total revenues and expenditures from CCD's FY 2015-16 Close-OutExpenditure Reports to their financial records and to WDACS's payment records.

Results

Six (67%) of CCD's nine FY 2015-16 Close-Out Expenditure Reports reconciled to theirfinancial records and to WDACS's payment records. However, three (33Yo) of theAgency's nine FY 2015-16 Close-Out Expenditure Reports did not reconcile to theirfinancial records. Specifically, CCD billed WDACS $373,545 for the three FY 2015-16Programs. However, their financial records for the three FY 2015-16 Programs indicatedthat their expenditures totaled $367,350, resulting in an overbilling of $6,195 ($3Zg,S¿S -$367,350). We noted a símilar finding in our prior year's monitoring report issued on April5,2017.

Recommendations

Community Gareer Development, lnc. management:

11. RepayWorkforce Development, Aging and Community Services $6,195.

12. Ensure that their Close-Out Expenditure Reports are based on actualexpenditures as required.

AU DITOR-CONTROLLERCOUNTY OF T-OS A'VGELES

Attachment II

Page 1 of 4

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october 3.2017

John NaimoAuditor-ControllerCounty of Los Angeles Department of Aud¡tor-ControllerKenneth Hahn Hall of Admin¡stration500 West Temple Street. Room 525Los Angeles, CA 90012-3873

RE: COMMUNITY CAREER DEVELOPMENT, lNC. - A WORKFORCEDEVELOPMENT, AGING AND COMMUNITY SERVICES PROGRAMS PROVIDER

- CONTRACT COMPLIANCE REVIEW JULY 20,16 THROUGH FEBRUARY 2017

Dear Mr. Naimo.

On behalf of Community Career Development. lnc. (CCD). I submit th¡s letter in responseto your report regarding the Commun¡ty Career Development, lnc. - AWorkforceÐevelopmenl, Agíng and Community Services Programs Provider - Contract CornplianceReview sampl¡ng transactions from July 2016 through February 2417 "

The following are CCD's responses to the recommendations noted:

ELIGIBILITY

RECOIJ|MENDATIONS

1. Review all Los Angeles County Youth Jobs Program expenditures billed to WorkforceDevelopment. Aging and Community Services during Fiscal Year 2016-17 to identiSany addit¡onal expend¡tures for ineligible clients charged to the Program, and repayany unallowable amounls.

CCD RESPONSÊ

':' CCD will review all Los Angeles County Youth Jobs Program expenditures billedto Workforce Development, Aging and Community Services during Fiscal Year2016-17 to identify any addit¡onal expenditures for ineligible clients charged tothe Program, and repay any unallowable amounts.

2. Repay Workforce Development. Ag¡ng and Communi$ Services $953.

CCD RESPONSË

.,, CCD will repay Workforce Development. Aging and Community Services $953"

3. fnsure that all Los Angeles County Youtlr Jobs Progrom clients are eligible toreceive Program services as required.

CCD RESPONSE

,:, CCD w¡ll ensure that all Los Angeles County Youth Jobs Program clients areeligible to receive Program serv¡ces as required.

PROGRAII/I SERVICES

RECOMMENDATIONS

Refer to Recommendations 1 and 3.

CCD RESPONSE

,:' Refer to CCD's Responses to Recommendations 1 and 3

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Attachment llPage 2 oi 4

Mr. John NaimoOctober 3.2017Page 2 ol 4

CASH/REVENUE

RECOMMENDATIONS

4. Repay Worklorce Development" Aging and Community Services 51.760. or provideWorkforce Development, Aging. and Community Services w¡th supportlngdocumentalion.

CCD RESPONSE

,:, There were 13 stale checks totaling $1.759.45. Of the 13 stale checks. t havebeen replaced and cashed in the amount of $1.459"48. 1 check was replaced butnot yet cashed in the amount of 573.16. and 3 are ín lhe escheatment processtotaling 5226.81.

:. CCD will provide Workforce Development, Aging. and Community Services withsupporting documentation of the escheat upon request and continue to follow upon the non-stale check lhat has not been cashed.

5. Resolve outstanding ¡tems in a timely manner-

CCD RESPONSE

,:, CCD will resolve outstanding items in a timely manner.

COST ALLOCATIOI,I PLA¡ITEXPENDITURES

RECOMMENDATIONS

6" Reallocate all shared expenditures charged to the Workforce Development. Aging.and Community Services Programs during Fiscal Year 2O16-17. provide WorkforceDevelopment. Aging and Community Services with supporling documentation. andrepay any unallowable or unsupported amounts.

ææNg,:, CCD r,vill reallocate all shared expenditures charged to the Workforce

Development. Aging. and Community Services Programs during FiscalYear2016-17 based on our t¡me study. We will reconcile based on the time study ofthe employees tested.

7 " Repay Workforce Development. Aging and Communig Services $1.260.

CCD RESPONSE

17 additionalparticipants were identified whom were provided supportiveservices in the amount of $20 gas gift cards. totaling 5340. CCD will providesupporting documentation to Workforce Ðevelopment. Aging and CommunityServices and repay Workforce Development. Aging and Communily Services lhebalance of $920 ($1,260-$340).

L Ensure that all expenditures charged to the Workforce Development, Aging andCommunity Services Programs are allowable. properly documented. andappropriately allocated.

CCD RESPONSE

: CCD will ensure that all expenditures charged to the Workforce Development,Aging and Community Servíces Programs are allor,vable, properly documented.and appropriately allocated.

9. Develop and implement policies and procedures to ensure that supportive servicesare available to Workforce lnnovation and Opportunity Act clients as required.

CCD RESPONSE

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Attachment llPage 3 of 4

Mr. John NaimoOclober 3.2017Page 3 of 4

CCD will develop and implement policies and procedures to ensure thatsupportive services are available to Workforce lnnovation and Opportunity Actclients as required.

FIXED ASSETS AND EQUIPTIENT

RECOMMENDATION

None.

ggs.Ë!!æNE,:, None

Atlùlll{¡STRATIVE COi'PLIANCE

RECOMMENDATION

None

CCD RESPONSE

,: None

PAYROLLAND PERSONiIEL

RECOi/IMENDATIONS

Refer to Recommendations 6 and 8.

CCD RESPONSE

.i Refer to CCD's Responses to Recommendations 6 and 8.

10. Community Career Development. lnc. managemenl ensure hours reported on clienttimecards are accurately calculated and clients are appropriately paid for their actualhours worked.

CCD RESPONSE

._, CCD management will ensure hours reported on client timecards are accuratelycalculated and clients are appropriately paid for their actual hours r,vorked.

CLOSE.OUT REVIEW

RECOMMENDATIONS

11. Repay Workforce Development. Aging and Communi$ Services $6.195.

CCD RESPONSE

.:, CCD will repay Workforce Development, Aging and Community Services $6.195.

't2. Ensure that their Close-Out Expenditure Reports are based on actual expendituresas required.

CCD RESPONSE

,:, CCD will ensure that our Close-Out Expendíture Reports are based on actualexpenditures as required supported by accounting records moving fon¡¡ard.

CCD willwork rvith Workforce Development, Aging and Communi$ Services inreconciling the final amount to be repaid.

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Mr. John NaimoOctober 3.2A17Page4 oî 4

Should you have any queslions or concems. please contact me at (213) 8O54273 orauribe@communiWcareer.orq. Thank you for your efforts in resolving these issues.

UribeExeculive Director

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