VAWA auditing
The U.S. Department of Justice Office of the Inspector General (OIG) audited the Office on Violence Against Women (OVW) Legal Assistance for Victims (LAV) grant (award 2016‑WL‑AX‑020, $1.2 million) awarded to the New York City Gay and Lesbian Anti‑Violence Project (AVP). The audit examined whether AVP’s expenditures, reporting, and internal controls complied with the DOJ Grants Financial Guide, award conditions, and federal law. Findings showed that AVP made adequate progress toward program goals (providing free legal services to LGBTQ and HIV‑affected survivors of sexual, domestic, dating violence, and stalking) but failed to maintain adequate written grant‑administration policies, to support personnel and fringe‑benefit costs with proper documentation, to allocate shared costs equitably, and to submit timely, fully supported performance reports. The audit questioned $748,076 in unsupported costs (personnel, fringe benefits, other direct costs) and $4,848 in unallowable pre‑award costs, for a total of $752,924. Ten recommendations were issued to OVW (and, by extension, to AVP) covering performance‑reporting policies, compliance with award conditions, federal grant‑administration policies, and remediation of the questioned costs. AVP submitted a detailed response contesting five recommendations, acknowledging late reporting, and describing corrective actions (new Salesforce database, revised grant‑management protocols, staffing changes). OVW’s response concurred with all recommendations and committed to coordinate with AVP to ensure implementation. The OIG’s final analysis marked all recommendations as “resolved” pending receipt of documented policy updates and remediation evidence. The report includes extensive tables of grant details, dollar‑related findings, and appendices containing the full responses from AVP and OVW.
Topics
Audit Scope, Objectives, and Methodology
Defines the audit’s purpose, the grant being examined, the period covered, and the audit standards and sampling methods used.
Financial Management Deficiencies – Missing Grant‑Administration Policies
Identifies the absence of written federal grant‑administration policies and procedures, and the resulting risks to compliance and continuity.
Personnel Cost Allocation Issues and Questioned Costs
Details how AVP allocated personnel salaries using estimated percentages rather than actual time, leading to $601,578 in unsupported personnel costs.
Fringe‑Benefit Rate Miscalculations and Questioned Costs
Explains the use of estimated fringe‑benefit rates instead of approved rates, resulting in $78,667 of unsupported fringe‑benefit expenditures.
Other Direct Cost Allocation and Shared‑Cost Equity
Analyzes AVP’s method of charging rent, utilities, and equipment lease costs directly to the grant, deeming $67,831 of other direct costs unsupported.
Compliance with Award Conditions – I‑9, PII, and Whistleblower Policies
Assesses AVP’s adherence to specific award conditions (employment eligibility verification, PII breach notification, employee rights disclosures) and notes partial non‑compliance.
Recommendations and OVW’s Concurrence
Lists the ten OIG recommendations, OVW’s agreement to each, and the commitment to coordinate remediation with AVP.
AVP’s Response – Contestations, Corrective Actions, and Ongoing Disagreements
Summarizes AVP’s detailed rebuttal to five recommendations, acknowledgment of late reporting, description of new Salesforce system, staffing changes, and policy revisions.