Overview
During the audit period, ORI did not always monitor the Citizenship for New Americans Program (CNAP). Specifically, ORI completed site visit checklists for only 7 out of 17 CNAP providers that provided services in fiscal year 2021 and the same 7 out of 17 CNAP providers that provided services in fiscal year 2022, and ORI did not complete site visit reports for these CNAP providers until 2023. Additionally, ORI told us that it did not record minutes for any meetings, kickoff conference calls, or fiscal year close conference calls that it held with CNAP providers.
By not performing monitoring activities over the CNAP, ORI risks funding providers that do not meet the goals of the program and further risks CNAP participants experiencing unnecessary delays in their paths to citizenship.
Authoritative Guidance
Section 207 of Chapter 6 of the General Laws states, “[ORI] shall have the following powers: . . . (c) to coordinate the commonwealth’s policies and programs for refugees and immigrants including those administered by other state agencies.”
Section M of ORI’s CNAP Additional Contract Requirements for fiscal year 2022 states,
Throughout [fiscal year 2022], ORI will monitor CNAP providers’ progress towards annual outcomes by performing a combination of activities that range from desk reviews and kick off conference calls at the beginning of the fiscal year to on-site monitoring reviews and Fiscal Year Close conference calls.
Reasons for the Issue
ORI told us that it delayed visiting some CNAP providers during the audit period because of a staffing shortage during the COVID-19 pandemic. ORI told us that it did not complete many fiscal year 2021 and 2022 site visits until its fiscal year 2023. Additionally, ORI told us that it could not complete site visits for 2 of the 10 CNAP providers with no site visits during either fiscal years 2021 or 2022 because they left the program.
Recommendations
- ORI should hold kickoff conference calls with CNAP providers at the beginning of each fiscal year.
- ORI should document meeting minutes for its kickoff conference calls and fiscal year close conference calls with CNAP providers.
- ORI should hold site visits with all CNAP providers at least annually during the fiscal year under review.
Auditee’s Response
ORI recognizes the importance of effective monitoring for its CNAP program. CNAP is a long-standing program for ORI. As such, it is imperative to note that during the audit period, the challenges posed by the pandemic and staff turnover significantly impacted the ORI’s monitoring activities and site visits to CNAP providers during the audit period. ORI is committed to regular monitoring activities, including conference calls, site visits, and desk reviews, as appropriate. ORI further recognizes the importance of documenting monitoring activities, including conference calls, to track this function and to ensure the availability of such records for audit reviews. ORI is reviewing its processes to ensure monitoring activities are documented in the program file.
ORI wishes to note one point of clarification related to the characterization of the “risk” related to the CNAP program, described above. As quoted above in ORI’s standard CNAP contract, ORI monitors “CNAP providers’ progress toward annual [target] outcomes.” As the Office of the Auditor is aware, providers are paid based on outcomes for individual clients. As such it does not seem quite accurate to note as a risk that ORI may be “funding providers that do not meet the goals of the program.” Providers and ORI set annual targets, and monitoring efforts relate to those annual targets to provide as much access to this program as possible. However, ORI only pays for outcomes and as such there is no risk of funding issuing to providers that “do not meet the goals of the program.” Funding only issues to providers that complete services consistent with the program requirements.
Auditor’s Reply
Although ORI recognizes the importance of its monitoring activities over the CNAP, in its response, ORI disagrees that by not performing monitoring activities, it may be funding providers that do not meet the goals of the program. ORI further states that this is because CNAP providers are paid based on the outcomes of their individual clients, with ORI’s payment serving as proof that the goals were achieved.
While it is true that CNAP providers are paid based on client outcomes, Section M of ORI’s CNAP Additional Contract Requirements for fiscal year 2022 established the following goal for ORI to monitor CNAP providers’ progress toward annual outcomes:
ORI will monitor CNAP providers’ progress towards annual outcomes by performing a combination of activities that range from desk reviews and kick off conference calls at the beginning of the fiscal year to on-site monitoring reviews and Fiscal Year Close conference calls.
Additionally, the CNAP Additional Contract Requirements for fiscal year 2022 also state that ORI should hold ongoing and fiscal year close calls to track whether CNAP providers are on track to meet their intended outcomes.
Finally, the CNAP Additional Contract Requirements also allow for ORI to conduct on-site fiscal monitoring of CNAP providers, including reviews of budget expenditures, billing, invoices, and payments to program employees. Therefore, we maintain that, by not performing its CNAP monitoring activities, ORI risks funding CNAP providers that may not be meeting annual outcomes of the program.
| Date published: | November 14, 2024 |
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