From April 2007 through March 2008, the OIG issued seven audit reports related to OJP’s human trafficking program. Five of the seven OIG audits evaluated individual cooperative agreements awarded by the OVC to provide services to victims of human trafficking. One OIG audit evaluated multiple cooperative agreements awarded to a single service provider. The remaining OIG audit evaluated a human trafficking task force grant awarded by the BJA. The OIG identified significant deficiencies during all seven audits including that grantees:

• did not meeting project goals,
  
  
• claimed unallowable and unsupported expenditures,
  
  
• drew down funds sooner than needed, and
  
  
• did not properly monitor subrecipients.

The OIG questioned $2,914,257 in grant expenditures and recommended $97,686 be put to better use.³¹ The OIG’s findings and recommendations for the seven audits are detailed below.

Cooperative Agreements

The OVC awards cooperative agreements to nongovernmental organizations to provide trafficking victims with comprehensive or specialized services. Comprehensive services include such basics as food, clothing, and shelter, as well as more proficient services such as legal assistance and advocacy, medical services, and jobs skills training. Specialized services are single services such as housing, legal assistance, or medical care that are provided over a broad geographic area.

The OIG reported on compliance with essential award conditions pertaining to goals and accomplishments, reporting, fund drawdowns, budget management and control, program income, local matching requirements, expenditures, indirect costs, monitoring of subrecipients, and accounting and internal controls.

Boat People S.O.S., Inc.

The OIG issued a July 2007 audit report on a cooperative agreement awarded to the Boat People S.O.S., Inc. (BPSOS) in Falls Church, Virginia.³² The OIG also tested the accounting records to determine if reimbursements claimed for costs under the award were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the cooperative agreement.

The OIG found that the BPSOS and its subrecipient, Ayuda, charged to the agreement over $700,000 in either unsupported or unallowable costs as shown below.

• BPSOS and Ayuda claimed $90,296 of expenditures for items that were not approved in the final budget. These expenditures included miscellaneous expenses, advertising, software, work study stipend, emergency assistance, and office insurance.
  
  
• The BPSOS and Ayuda fringe-benefit costs contained numerous calculation errors. Because of these errors and lack of supporting documentation, the BPSOS and Ayuda could not support $77,588 and $36,272, respectively, of fringe benefit costs charged to the agreement.
  
  
• The BPSOS’s method of allocating indirect costs to the agreement resulted in the grantee claiming $152,583 in excess indirect costs.
  
  
• The BPSOS provided inadequate supporting documentation for local match transactions, resulting in unsupported pro bono attorney fees of $294,575.
  
  
• The BPSOS claimed over $57,000 in local matching funds that were not approved by OJP.

The OIG also found that BPSOS did not achieve many of the agreement objectives including, establishing a rapid response team, creating an annual directory of service providers, developing an advisory board, or conducting the agreed upon number of seminars.

Among its 22 recommendations, the OIG urged the OVC to:

• remedy the $90,296 of unapproved BPSOS and Ayuda expenditures.
  
  
• ensure that the grantee implements adequate procedures to identify and monitor approved expenditures.
  
  
• remedy the $152,583 questioned indirect costs.
  
  
• remedy the $294,575 questioned pro bono legal local match.
  
  
• ensure that the grantee implements a methodology for appropriately allocating pro bono work to the grant.

OJP agreed with 21 of the 22 recommendations and provided planned or completed corrective actions for them. OJP disagreed with the recommendation to remedy the $2,800 in questioned dental and life insurance costs and said that the questioned amount was for dental insurance which was allowable under the budget category of health insurance. In its response to the OIG audit, the Boat People objected to some of the report language that did not have a significant effect on the reported deficiencies. The Boat People either in most cases agreed with the OIG’s recommendations and provided planned or completed corrective actions to address the deficiencies, or provided additional explanations for deficiencies identified by the OIG.

Heartland Alliance for Human Needs and Human Rights

The OIG issued a January 2008 audit report on multiple cooperative agreements awarded to the Heartland Alliance in Chicago, Illinois.²⁸ The OIG also tested the accounting records to determine if reimbursements claimed for costs under the awards were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the agreements.

The OIG found the following deficiencies:

• Heartland Alliance was unable to identify and account for, in total and by budget category, which expenditures received federal reimbursement.
  
  
• The grantee’s control over expenditures was inadequate to ensure that expenses were allowable or properly supported. The OIG identified $1,501,823 of federally reimbursed costs charged to the agreements that were unallowable or inadequately supported.
  
  
• Match expenditures totaling $173,589 were unsupported or unallowable.
  
  
• Weaknesses existed in Heartland Alliance’s procedures to report on agreement activity, including determining, requesting, and recording drawdowns, as well as filing timely and accurate financial status reports.

Of the 23 recommendations addressed to OJP, the OIG urged it to:

• Ensure that Heartland Alliance establish procedures so that receipts and expenditures are timely and accurately entered into the agreement accounting records, and that requests for reimbursements are based upon uncompensated expenditures to-date.
  
  
• Remedy the $902,122 in questioned costs for the three agreements resulting from salary expenditures that lacked adequate support.²⁹
  
  
• Remedy the $174,479 in questioned costs for the three agreements resulting from fringe-benefit expenditures that lacked adequate support.
  
  
• Remedy the $162,012 in questioned costs for two agreements resulting from direct expenditures that lacked adequate support.
  
  
• Remedy the $63,009 in questioned costs for one agreement resulting from pro-bono expenditures in excess of the maximum daily allowable rate.

OJP agreed with all 23 recommendations and provided planned or completed corrective actions for the recommendations. In its response to the OIG audit, Heartland Alliance generally agreed with the OIG’s recommendations and provided planned or completed corrective actions for them.

International Rescue Committee – Miami

The OIG issued a March 2008 audit report on a cooperative agreement awarded to the International Rescue Committee (IRC) in Miami, Florida.³³ The OIG also tested the accounting records to determine if reimbursements claimed for costs under the award were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the agreement.

Among the deficiencies the OIG found the following:

• The IRC did not achieve the objectives pertaining to social services and legal services because it did not serve 100 victims as anticipated, and did not obtain 80 T-visas as anticipated for victims of trafficking identified during the project period.
  
  
• The IRC did not maintain supporting documentation for eight of the clients enrolled to show how IRC staff determined the clients were eligible for the program. The OIG questioned $17,536 for direct assistance costs related to these eight clients as unsupported.
  
  
• The IRC did not clearly identify the number of new clients in the program progress reports. Moreover, the IRC did not clearly identify the status of each client’s legal achievement of obtaining a T-visa or other appropriate forms of immigrant relief in the progress reports.
  
  
• The IRC did not maintain sufficient records for an audit trail to trace the details of the reimbursement requests to the accounting records.
  
  
• The IRC was unable to provide supporting documentation for client housing costs. The OIG questioned $2,300 as unsupported costs that the IRC claimed as direct costs for victim housing.

• The IRC entered into agreements with subrecipients to provide housing, medical, and legal services, for which the IRC paid them nearly the full amounts budgeted in the agreement. However, the subrecipients provided services to fewer victims than the budget was established to support. The OIG questioned $297,686 of these direct costs as unsupported.
  
  
• The above findings related to direct costs had an effect on the accuracy of the indirect costs as reported by the IRC. The IRC staff told the OIG that they calculated the indirect costs for reimbursement by using the base of direct costs multiplied by the approved indirect cost rate. Therefore, the OIG questioned the accuracy of the calculation of the indirect costs by $6,843 as well as unsupported costs.
  
  
• The above findings related to direct costs also had an effect on the reporting accuracy of the local matching costs. Since the OIG questioned client eligibility and costs paid to the subrecipients as unsupported, the OIG also questioned an equal portion of the related local match in the amount of $163,337.
  
  
• The IRC did not monitor its subrecipients by conducting periodic on-site visits that included both programmatic and financial reviews, as OJP had suggested.

Among the 17 recommendations, the OIG urged OJP to:

• Ensure grantees adjust strategic plans appropriately to address their challenges in meeting objectives or deobligate funds to award to other applicants.
  
  
• Ensure that the IRC consistently maintains more comprehensive intake information in the social service case files to document the victim’s eligibility at the time of enrollment.
  
  
• Ensure the IRC maintains support to trace reimbursement requests to its accounting records.
  
  
• Remedy the unsupported costs of $297,686 related to housing, legal services, and mental health services provided by the Salvation Army, Florida Immigrant Advocacy Center, and Victim Services Center.
  
  
• Remedy the unsupported costs of $163,337 related to local match funds.

OJP agreed with 15 of the 17 recommendations and provided planned or completed corrective actions for them. OJP disagreed with the recommendation regarding deobligation of funds not used for direct assistance to victims and the recommendation for the International Rescue Committee to issue a protocol for coordinating with external agencies. OJP also disagreed in part with the recommendation regarding unused housing services. In its response to the OIG audit, the International Rescue Committee disagreed with all 17 recommendations, but provided planned actions to resolve many of them.

Mosaic Family Services, Inc.

The OIG issued an April 2007 audit report on a cooperative agreement awarded to Mosaic Family Services, Inc., in Dallas, Texas.³⁵ The OIG also tested the accounting records to determine if reimbursements claimed for costs under the agreement were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the agreement.

The OIG found that on multiple occasions, Mosaic drew down more funds than needed from OJP to meet current expenses. In addition, Mosaic could not support $41,318 in agreement expenditures. Further, Mosaic performed infrequent monitoring of its two subrecipients.

The OIG recommended that the OVC:

• remedy the $41,318 in unsupported direct costs and personnel expenses, and
  
  
• ensure Mosaic directed the Center for Survivors of Torture, a subrecipient, to develop and implement a methodology for tracking employee time spent working on the agreement.

Both OJP and Mosaic agreed with the recommendations and provided documentation to address the weaknesses found. The OIG closed the audit report based on the documentation provided.

Refugee Women’s Network, Inc.

The OIG issued a July 2007 audit report on a cooperative agreement awarded to the Refugee Women’s Network, Inc. (RWN), in Decatur, Georgia.³⁴ The OIG also tested the accounting records to determine if reimbursements claimed for costs under the award were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the agreement.

The OIG found that RWN and its subgrantee, Tapestri, performed required activities and were in the process of accomplishing three of the cooperative agreement goals. However, the OIG found that two goals apparently could not be met. Although RWN and Tapestri staff made efforts to perform outreach and identify victims of human trafficking, they had served only 21 potential victims, of whom only 5 had been certified as victims of human trafficking. In addition, eight clients were found not to be victims of human trafficking. The OIG identified $97,686 in funds to be put to better use and $15,788 in questioned costs. The OIG also identified weaknesses in the subgrantee’s accounting practice.

The OIG made six recommendations to OJP including:

• deobligate $97,686 that remained unexpended at the end of the initial award period,
  
  
• ensure that RWN and Tapestri established controls to ensure proper compliance with local match requirements, and
  
  
• ensure that Tapestri established adequate internal controls to safeguard federal funds.

OJP disagreed with the first recommendation to deobligate the $97,686 that remained at the end of the initial agreement period. In its response to the OIG audit, RWN disagreed with the recommendations related to deobligating the remaining agreement funds, remedying $8,463 in overcharges for salaries and fringe benefits, and establishing internal controls to safeguard federal funds. RWN generally agreed with the remaining three recommendations.

YMCA of the Greater Houston Area, Inc.

The OIG issued an April 2007 audit report on a cooperative agreement awarded to the Young Men’s Christian Association (YMCA) of the Greater Houston Area.³⁶ The OIG found that the YMCA was in compliance with the essential agreement conditions except for the areas of reporting and expenditures.  The YMCA did not submit some progress reports in a timely manner. In addition, the YMCA could not support $21,120 in costs charged to the agreement.

Among the seven recommendations, the OIG urged the OVC to:

• remedy the $21,120 in unsupported questioned costs;
  
  
• direct the YMCA to establish procedures to ensure that all expenditures charged to the program are in accordance with the program guidelines; and
  
  
• direct the YMCA to establish procedures to ensure that employee salaries and fringe benefits charged to the program are verified as correct, and ensure fringe benefits charged to the program can be isolated and identified for each individual employee whose benefits are charged to the program.

OJP agreed with six of the seven recommendations and provided planned or completed corrective actions for them. OJP disagreed with the recommendation related to submitting progress reports in a timely manner. In its response to the OIG audit, the YMCA generally agreed with six of the seven OIG’s recommendations and provided planned or completed corrective actions for them. However, the YMCA also disagreed with the recommendation related to submitting progress reports in a timely manner.

Grants

The BJA began awarding grants in FY 2005 to state and local law enforcement agencies to develop task forces that identify and rescue victims of human trafficking. In the grant audit listed below, the OIG reported on compliance with essential award conditions pertaining to accomplishment of grant objectives, accounting and internal controls, grant reporting, grant drawdowns, budget management and control, local matching funds, grant expenditures, program income, and monitoring of subgrantees.

San Diego Regional Anti-Trafficking Task Force

The OIG issued a January 2008 audit report for a grant awarded to the County of San Diego, California.³⁰ The OIG also tested the accounting records to determine if reimbursements claimed for costs under the awards were allowable, supported, and in accordance with applicable laws, regulations, guidelines, and the terms and conditions of the grants.

The OIG found the following deficiencies:

• The Sheriff’s Department maintained an accounting system and financial records that did not always separately account for grant-related expenditures and revenue.
  
  
• The Sheriff’s Department charged an unauthorized position to the grant.
  
  
• The Sheriff’s Department did not always submit timely progress reports.
  
  
• The Sheriff’s Department was not meeting the grant objectives laid out by OJP as it relates to investigating human trafficking cases as well as identifying and caring for victims of human trafficking.

The OIG recommended that OJP:

• Ensure that the grantee has appropriate controls in place to ensure that all grant-related transactions are properly posted under the unique grant-designated fund number to avoid commingling expenditures and revenue with those of other grants or projects.
  
  
• Ensure that the Sheriff’s Department does not claim extra overtime pay resulting from charging the higher salaried sergeant position to the grant rather than the lower salaried deputy position that is included in the OJP-approved grant budget.
  
  
• Ensure that the Sheriff’s Department submits the required semi-annual progress reports within the allowable timeframe.
  
  
• Ensure that the grantee applies its focus for the remainder of the grant toward fulfilling the program objectives relating to investigations of human trafficking cases as well as the identification and care of human trafficking victims.
  
  
• Ensure that the Sheriff’s Department, in its semi-annual progress reports to OJP, continually and accurately reports on the number of human trafficking victims identified through task force efforts, providing sufficient detail with regard to the efforts that have been presented in identifying and properly handling the victims of such investigations.

OJP agreed with all five recommendations and provided planned or completed corrective actions for them. In its response to the OIG, the San Diego Sheriff’s Department generally agreed with the OIG’s recommendations and provided planned or completed corrective actions for them.

28. The $2,914,257 questioned included $375,000 that was for award number 2002-WL-BX-0026 which was not a human trafficking service provider award as explained in footnote 20.

29. U.S. Department of Justice, Office of the Inspector General, Office for Victims of Crime Victims of Exploitation and Trafficking Assistance Grant Awarded to Boat People S.O.S., Inc., Falls Church, Virginia, Award Number 2004-VT-BX-K009, Audit Report GR-30-07-004 (July 2007).

30. U.S. Department of Justice, Office of the Inspector General, Office of Justice Programs Legal Assistance for Victims Grant and Services for Human Trafficking Victims Discretionary Grants Administered by the Heartland Alliance for Human Needs and Human Rights, Chicago, Illinois, Award Numbers 2002-WL-BX-0026, 2003-VT-BX-K002, and 2003-VT-BX-K003, Audit Report GR-50-08-002 (January 2008).

31. The $902,122 questioned included $220,170 that was for award number 2002-WL-BX-0026 which was not a human trafficking service provider award as explained in footnote 20.

32. U.S. Department of Justice, Office of the Inspector General, Office of Justice Programs Office for Victims of Crime Services for Trafficking Victims Discretionary Grant Program Cooperative Agreement Awarded to the International Rescue Committee, New York, New York, Award Number 2003-VT-BX-K011, Audit Report GR-40-08-003 (March 2008).

33. U.S. Department of Justice, Office of the Inspector General, Services for Trafficking Victims Discretionary Grant Program Cooperative Agreement Awarded to Mosaic Family Services, Inc., Award Number 2003-VT-BX-K005, Audit Report GR-80-07-006

34. U.S. Department of Justice, Office of the Inspector General, Office of Justice Programs Office for Victims of Crime Services for Trafficking Victims Discretionary Grant Program Cooperative Agreement Awarded to Refugee Women’s Network, Inc., Decatur, Georgia, Award Number 2004-VT-BX-K010, Audit Report GR-40-07-005 (July 2007).

35. U.S. Department of Justice, Office of the Inspector General, Services for Trafficking Victims Discretionary Grant Program Cooperative Agreement Awarded to the YMCA of the Greater Houston Area, Award Number 2003-VT-BX-K007, Audit Report GR-80-07-007 (April 2007).

36. U.S. Department of Justice, Office of the Inspector General, Office of Justice Programs, San Diego Region Anti-trafficking Task Force Grant Awarded to the County of San Diego, California, Audit Report GR-90-08-001 (January 2008).