HomeMy WebLinkAbout07/10/2025 Audit Monroe County Clerk of Circuit Court & Comptroller
Internal
rp
fw,�y �i"wawwma'w„�
Audit of
Monroe County
Social Services
Grants Management
2025-003
500 Whitehead Street, Key West, FL 33040 1 (305) 295-3130 1 Monroe-Clerk.com
Report 2025-003
July 2025
Monroe County Clerk of Circuit Court& Comptroller
Kevin Madok, CPA
Interim Internal Audit Director
Pam Radloff
Auditors
Tammie Murray
About Monroe County Clerk's
Internal Audit Department
As part of the Clerk's constitutional responsibilities, the Monroe County Cleric's
Internal Audit Department provides independent, accurate, and timely audits of
Monroe County government's business activities, operations, financial systems, and
internal controls. Internal Audit's audits and consulting services are designed to add
value, increase efficiency of operations, advance accountability, and improve
stewardship of public resources.
Monroe County's Internal Audit Department accepts confidential tips about fraud,
waste, and abuse in Monroe County government or prograins through its hotline
(305)292-5760 or at htttps://monroe-clerlc.com/fraud-waste-abuse.
Kevin Madok, CPA
Yp6 F
�toN..... �..v Clerk of the Circuit Court&Comptroller—Monroe County, Florida
July 10,2025
The Honorable Mayor Jim Scholl
Monroe County Board of County Commissioners
530 Whitehead Street
Key West,FL 33040
Email: boccdis3(q),monroecounty-fl.gov
Dear Mayor Scholl:
The Monroe County Clerk's Internal Audit Department completed an audit of Monroe County's Social Services
Department's(MOSS)management of its Federal and state grant programs for the audit period October 1,2021,
through September 30, 2024. Our audit found serious mismanagement of MOSS' grant funds and related
programs.
Over the past few years, Federal and state granting agencies have repeatedly reported audit deficiencies with
MOSS' grants management related to responsiveness, nutrition compliance, and program expenditures. We
reviewed available documents to determine if there was an underlying cause for MOSS'inability to be responsive
to granting agencies as well as its inability to be compliant with grant requirements. We found that the leading
causes were that MCSS lacks consistent operational policies and procedures and has an ineffective organizational
structure.
MOSS'unstructured work environment created an opportunity for MCSS to seriously mismanage its grant funds
which, in turn, appears to have created a material budget shortfall for the County. Although determining the
amount falls outside the scope of this audit, the shortfall could possibly exceed $2 million. The primary cause
appears to be MCSS regularly posting expenditures to expired grants. In other words, MCSS management did
not ensure that grant revenue was available to cover the department's expenditures. We recommend the BOCC
take immediate steps to address the potential budget shortfall by conducting a year-by-year review of MCSS
grants to verify that grant expenditures are matched to actual grant revenue received.
We appreciate the courtesy and cooperation extended to the Clerk's Office by MCSS staff during the audit.
MOSS'responses to our audit recommendations are included in the body of the audit report.
Sincerely,
Kevin Madok, CPA
Monroe County Clerk of Circuit Court&Comptroller
Cc: Board of County Commissioners
Christine Hurley, County Administrator
Tina Boan,Assistant County Administrator
Bob Shillinger, County Attorney
Internal Audit
KEY WEST MARATHON PLANTATION KEY
500 Whitehead Street 3117 Overseas Highway 88770 Overseas Highway
Key West, Florida 33040 Marathon, Florida 33050 Plantation Key, Florida 33070
Table of Contents
Audit of
Monroe County Social Services
Grants Management
ExecutiveSummary...................................................................................... 1
Monroe County Social Services Grant Programs ...................................... 3
Purposeand Scope of Audit ......................................................................... 5
Lack of Operational Efficiency and Compliance ....................................... 6
Lack of Defined Workflow and Operational Policies..................................................................6
Paper-Based Operations...............................................................................................................9
StaffingConcerns.......................................................................................................................13
Financial Management and Budget Concerns.......................................... 17
Mismanagement of Grant Funds................................................................................................17
Improper Approval and Budgeting of Grant Awards.................................................................22
SHIPProgram Oversight............................................................................................................26
Executive Summary
Monroe County's Social Services Department (MOSS) is tasked with managing programs that
provide interim financial assistance, medical assistance, and other life-sustaining supportive
assistance to eligible individuals and families in need throughout Monroe County. MCSS staff
counsel clients to refer them to the applicable local, state, and Federal programs and agencies that
can assist these individuals and families in need of long-term support with the goal of reducing
social and economic dependency. MCSS is headed by the Senior Director of Social Services who
is responsible for managing both the department staff and its various programs that primarily
depend on funding from Federal and state grant awards.
Relying on Federal and state grants for financing its program operations requires MCSS to
continually demonstrate that staff are adhering to the terms of the grant awards and meeting a
grant's stated program objectives. To that end, granting agencies conduct compliance reviews and
issue monitoring reports that summarize the County's successes and/or failures for meeting
program objectives.When a granting agency identifies issues or concerns,the grantee must prepare
a corrective action plan. Over the past few years, MCSS has been placed on multiple corrective
action plans due to ongoing issues related to responsiveness, nutrition compliance, and program
expenditures. Because of the concerns regarding the audit deficiencies noted by granting agencies,
the Monroe County Clerk& Comptroller Internal Audit Department performed an audit of MOSS'
grant management for Fiscal Years 2022, 2023, and 2024.
As part of our audit, we interviewed MCSS staff and reviewed available documents to determine
if there was an underlying cause for MOSS' inability to be responsive to granting agencies as well
as its inability to be compliant with grant requirements. We found that a leading cause was that
MCSS management does not have defined workflows and no consistent operational policies for
the department that would allow staff to readily respond to granting agencies. We also found that
MOSS' operations are primarily paper-based which also creates needless delays in responding.
Lastly, we found staffing to be mismanaged and the department's overall organizational structure
to be operationally ineffective.
MOSS' unstructured work environment created an opportunity for MCSS to seriously mismanage
its grant funds. We examined records to determine whether MCSS was maximizing its grant
funding. This included reviewing MOSS' approved BOCC budgets and evaluating the timeliness
and effectiveness of MOSS' reimbursement requests to granting agencies. We also attempted to
reconcile MOSS' approved budget to the actual revenues and expenditures posted in the County's
accounting records for the department's various grant programs. Our review found serious
mismanagement of grant funds by MCSS management that appears to have created a material
— 1 —
budget shortfall for the County. Although determining the amount falls outside the scope of this
audit, initial estimates suggest that the shortfall could possibly exceed $2 million.
The primary cause appears to be MCSS regularly posting expenditures to expired grants.
Additionally, it appears MCSS does not report grant awards to the Office of Management and
Budget in a timely manner, resulting in the failure to adjust the department's operational budgets.
We also found that MCSS management is not properly prioritizing and managing its assistance
programs to maximize the County's grant funding resources. If not properly and promptly
managed, significant grant funds originally designated for Monroe County could ultimately be
reapportioned and given to other Florida counties.
Our audit report contains recommendations for the Board of County Commissioners (BOCC) to
consider. Of immediate concern is for the BOCC to take steps to address the potential budget
shortfall caused by MOSS' mismanagement of grant funds. We strongly recommend that the
BOCC have staff go back a number of years to conduct a year-by-year review of MCSS grants to
verify that grant expenditures are matched to actual grant revenue received. Once this review is
complete, a plan needs to be developed to properly fund any unmatched grant expenditures.
Monroe County Social Services Grant Programs
Monroe County's Social Services Department's (MOSS)stated mission is to provide". . . a holistic
approach to case management, interim financial assistance, medical assistance, and other life-
sustaining supportive assistance,to eligible individuals and families in need of services throughout
Monroe County."' MCSS designs the assistance it provides to restore their clients to self-
sufficiency or to maintain and promote independent self-management. MCSS staff counsel their
clients to refer them to the applicable local,state,and Federal programs and agencies that can assist
these individuals and families in need of long-term support. The goal of MCSS' programs is to
reduce social and economic dependency.
MCSS is headed by the Senior Director of Social Services and reports directly to the Assistant
County Administrator. Currently, budget documents show MCSS has 14.59 full-time equivalent
(FTE) positions that are funded with ad valorem taxes. Moreover, MCSS has additional program
staff that are expected to be exclusively funded through the department's grant programs,bringing
MCSS total staffing to 56 full-time and part-time positions. These individuals assist clients
throughout Monroe County. MCSS' headquarter office is located in Key West. There is also a
satellite office in Key Largo. Staff also manage established meal sites in Key West, Big Pine Key,
and Key Largo.
MCSS prioritizes its resources to serve the elderly, low-income individuals, and families with
children under the age of six. MCSS oversees and manages a variety of social service programs
some of which provide services directly to clients while others provide direct financial assistance
to clients.
MCSS' programs that provide direct client-services include:
• In-homes services: Provides support services to eligible clients 60 years or older for such
tasks as homemaking, chores around the house, companionship, shopping assistance, and
personal care. the Federal Older Americans Act (OAA) grants fund these services and
Monroe County must match the grant with ten percent of local dollars.
• Nutrition services: Provides clients who are 60 years or older with nutrition counseling;
congregate meals served at established meal-site locations; or home-delivered meals to
home-bound clients who are unable to attend congregate meals due to physical, mental, or
medical limitations. Monroe County must match with ten percent of local dollars for
Monroe County Adopted Annual Operating&Capital Budget,Fiscal Year 2025,p.310.
— 3 —
funding the program. The Federal government also provides additional funding through its
Nutrition Services Incentive Program (NSIP)to encourage grantees to serve more people.
• Alzheimer's Disease Initiative (ADI): Funds in-home care, facility-based care, and
caregiver support for persons 18 years or older who are afflicted with Alzheimer's Disease
and other forms of dementia. ADI allows MCSS staff to work with family members and
caregivers so eligible clients live as independently as possible. In addition to caregiver
counseling and training, the state grant program also helps fund respite care that allows
temporary relief to caregivers.
• Enhanced Mobility for Seniors and Individuals with Disabilities: MCSS also
periodically receives funding to purchase specially equipped buses and vans for older
adults and people with disabilities. The Florida Department of Transportation (FDOT)
funds the Monroe County Transportation (MCT) program to meet these specialized
transportation needs.Monroe County must match the grant with ten percent of local dollars.
MCSS programs that provide financial assistance to clients include:
• Low-Income Home Energy Program (LIHEAP): Provides income-qualified families
with Federal financial assistance home heating and cooling costs. MCSS determines
eligibility and pays the utility company directly on behalf of eligible County residents.
• Weatherization Assistance Program(WAP):Provides income-qualified households with
Federal financial assistance to make energy efficient improvements to the home. The goal
is to reduce the monthly energy costs incurred by low-income households. As a first step
in determining eligibility,the WAP program requires a certified energy auditor to complete
a required in-home inspection to analyze energy usage and identify conservation
opportunities for the household. MCSS has opted to rely on staff to obtain the require
energy auditor certifications. At completion of a weatherization project, an independent
Quality Control Inspector performs a final inspection.
• State Housing initiatives Partnership Program (SHIP): Provides state funds to local
governments as an incentive to create partnerships that produce and preserve affordable
homeownership and multifamily housing. In 2018, MCSS assumed the responsibility of
this program from the Monroe County Housing Authority.
� 4 �
Purpose and Scope of Audit
To ensure the proper use of grant funds, granting agencies conduct compliance reviews. A
monitoring report details whether the grantee is meeting program objectives and complying with
the grant's guidelines and regulations. When the granting agency identifies issues or concerns,the
grantee must prepare a corrective action plan (CAP). Over the past few years, MCSS has faced
challenges after being placed on multiple CAPS. Since its 2022 monitoring, MCSS has been under
a CAP for their OAA and ADI programs due to ongoing issues related to responsiveness,nutrition
compliance, and program expenditures. In 2024, additional concerns arose, including service
continuity and client eligibility, leaving multiple CAP items unresolved.
Further, following a 2023 compliance review, FDOT placed MCSS on an additional CAP due to
multiple deficiencies in policies and operating procedures, including vehicle maintenance,
training, driver files, and civil rights compliance. However, as of September of 2024, MCSS
successfully addressed FDOT's findings, leading to the resolution of this CAP.
Due to concerns regarding the audit deficiencies noted by granting agencies,Monroe County Clerk
& Comptroller requested the Internal Audit Department to perform an audit of MOSS' grant
management. The audit period was for a three-year period, Fiscal Years (FY) 2022 through 2024.
The scope of the audit included an examination of:
• Grant management policy and procedures;
• Grant management effectiveness, efficiency and cost effectiveness, including and timeliness
of reporting and desired programmatic outcomes;
• Prioritization of resources for managing grants, including compliance with agency monitoring
and addressing audit findings;
• Managing adherence to grant compliance requirements, applicable laws and regulations,
including, contract deliverables and file documentation; and
• Maximization of grant funding, including proper budgeting for match requirements.
Lack of Operational Efficiency and Compliance
MOSS' granting agencies regularly monitor and report on whether MCSS is meeting contract
deliverables. In recent years, the Alliance for Aging, Inc., (the Alliance), the granting agency for
the OAA and ADI grants, advised MCSS that the results of their monitoring concluded that MCSS
is not in compliance. In fact, the Alliance sent repeated demand letters to MCSS because MCSS
did not submit all requested information to complete the annual monitoring. The Alliance
concluded in June 2023 that MCSS was in violation of its contract for failing to produce the
requested documents.
MOSS' inability to be responsive to granting agencies appears to be a repeating pattern. As part of
our audit,we interviewed MCSS staff and reviewed available documents to determine if there was
an underlying cause for MOSS' noncompliance with grant requirements. We found that MCSS
management does not have defined workflows and consistent operational policies for the
department to allow staff to readily provide the information granting agencies are requesting. We
also found that MOSS' operations are primarily paper-based which also creates needless delays in
responding. Lastly, we found staffing to be mismanaged and the departments' overall
organizational structure to be ineffective.
Lack of Defined Workflow and Operational Policies
Within MOSS, the same responsibilities are assigned to multiple staff instead of a designated
individual, essentially weakening accountability. Without clear ownership, tasks can be
overlooked, and it becomes difficult to track performance or address performance issues.
Communication gaps may arise as employees assume others will handle aspects of the work,
leading to delays or mistakes. Additionally, when issues occur, determining responsibility and
implementing corrective action becomes challenging.
For example, when conducting their annual monitoring,the Alliance requires the grantee to detail
the corrective action that will be taken in response to identified issues. The lack of defined
workflow is evident in MOSS' response in their CAP (see Exhibit 1). The Alliance found that
MCSS is not timely, and at times non-responsive, to data requests. Instead of assigning a single
staff person to be the gatekeeper for all data requests, MCSS management response was to require
the Alliance to copy three senior MCSS staff whenever making a request. MOSS' rationale for
requiring three staff to be alerted was because senior staff are managing multiple programs
throughout the workday and may be away from their computers for long periods of time when a
request is made. MOSS' response does not make one person accountable for handling the request.
— 6 —
Rather, it allows senior MCSS staff to assume someone else in the email string will take care of
the request since they are busy with other priorities and are regularly away from their computers.
Exhibit 1
Excerpt from MOSS Corrective Action Plan for OAA and ADI Grants
Ili FMIOINS11II "III"N i �v
The provider is responsible for responding;in a timely fashion to additional routine and/or special requests for
information and reports required by the Alliance.(COAA Contract,Attachment I,Section II.D.;ADI Contract,
Attachment.I,Section H.D.).
The Alliance contirmues to experience difficulties obtaining timely responses from.NICSS,. Information must be
requestal multiple,times before it is received,and irm some cases„it is never submitted,
OBJECTIN E'1: The Provider will acknowledge receipt of requests for information from the Alliance,.
provide information to the Alliance by the requested due date,,and request extensions to
time deadlines in writing to the Contract NIanager prier to the dove date,if necessary,.
TARGET COMPLETION DATE:'
fwfav'1 2023
ACTION STEP I If Monroe Conwvty Social Services receives email from the Alliance for Aging for
"additional routine andrar special requests":,DR receives email reminder from the
Alliance for Aging for missing or folloiv up documentation;OR receives email or
auto generated Adobe Sign email re,gardirvg contracts or contract amnenvdmenrts,w'�,e
wmll respond within eight(S)business hours that the reques6emarl has been Ma", t ,fl'3
received. If iwe are aLle to,immediately provide a sufficient and complete
response/solution,it mll be provided within E business hovers. If additr(ml
research and/or information is required,we vw^rll adhere to your assigned deadline..
If we need additional time beyonvd the assigned deadlirne,we wwrll provide a detailed
explanation as to why and an extension to the deadline will be requested-
PERSON The people responsible for tlrrs assv_�rrcvtient vhrll be multi-falld. DATE COMPLETE rt 102 i
RE4PONSII In rd f4,x„us to be successful in this objective,we need to ;?oiiioii f N,t'&Iv a rt alKd a&a
ensure that ALL'T'HREE(3)Senior staff with Monroe County -';iu
Sociall,Serve ices are ALWAYS copied on ALL requests from the,
Alliance for Aging_ Because MCSS staff are engaged in
multiple programs throughout the day„and may be away from
office electronic dew;ices for'long periods of time,ALL requests
from the Alliance must be sent to all the following individuals
to ensure a timely receipt and response:
t,) Sheryl Graham,
............................
2) Kim Wilkes weans,
3) 7enna.Tuttle,
Another example where MCSS does not have either a defined workflow or clear operational
policies is MOSS' lack of a centralized client intake process. The intake process is initiated with a
referral. Referrals may originate from multiple sources at multiple locations, including self-
referrals, and may be walk-ins, phone calls, or emails. MCSS has no designated staff member
responsible for ensuring that all referrals received are addressed timely and appropriately.
Because of the lack of a defined workflow for handling referrals,we were unable to conduct audit
procedures that would determine the number of referrals and whether there was an adequate
response time or assigning client services was effective. When we communicated our concerns
— 7 —
regarding the lack of a standardized process, MCSS management response was to establish an
intake email address to facilitate information sharing and client status tracking. However, we still
have concerns that this new procedure will not provide the most effective means of managing new
client intake or ensure comprehensive management oversight.
Further, while MCSS staff do their best, MCSS management has not established procedures to
ensure that an effective holistic review is completed of clients' needs and that clients are screened
for all possible services/programs. This lack of structure increases the risk of delay in providing a
client service, increases the likelihood of cases being overlooked, or allows the possibility of
favoritism.
We recommend MCSS:
• Review and document all MCSS workflows and ensure that the workflows are supported
by established policies and procedures and staff are assigned to defined roles and
responsibilities. When conducting this review, MCSS should ensure that procedures and
internal controls are established to allow staff to be responsive to all clients and all clients
are processed as required by established policy.
• Develop a centralized intake and tracking system that will allow for proper case
management. A centralized intake and tracking system should allow MCSS staff to easily
determine the status of a client and develop procedures to require regular management
oversight of staff's responsiveness and effectiveness of service assignments.
• Establish more effective procedures that will ensure MCS management is timely in
responding to requests made by granting agencies.
Management Response:
• MCSS agrees with this recommendation.We are currently initiating a comprehensive review
of all departmental workflows and business processes.As part of this review:
— We will evaluate all critical workflows.
— We will clearly assign responsibilities to individual staff members to ensure
accountability and traceability.
— Updated procedures will include internal controls to ensure all clients and requests are
handled consistently and in accordance with policy.
— Staff training in the new workflows and responsibilities will be scheduled and completed
— 8 —
Management Response(continued):
• MCSS concurs that a centralized intake and case management system is needed. In response,
we will:
— Look at the feasibility of establishing a dedicated intake email address as a preliminary
step. But,to go further,we will also create a standard application that all applicants will
be required to fill out and submit. Each application will be assigned a case number and
a case worker, depending on the type of need, case workers will be responsible for
processing the application. As an interim measure we will utilize our web-based tools to
create an application to formally document submittal. If an applicant is unable to access
the web, caseworkers can assist them, thereby assuring their request is documented and
processed.
— Begin evaluating software options, for a long-term solution, for a more robust case
management system that will allow for real-time tracking of referrals, client status, and
service assignments.
— Be committed to implementing a system that includes reporting features for ongoing case
management oversight and performance monitoring.
— For each individual program: In-home services; Nutrition; Alzheimer's Disease
Initiative; Enhanced Mobility for Seniors and Individuals with Disabilities; LIHEAP;
WAP; and SHIP we will establish a workflow, as well as a formal protocol with internal
goals for responding to requests.
• MCSS fully agrees that communication with granting agencies must be improved.
— We will designate a single staff member, in addition to the director, as the primary liaison
for all grantor communications and data requests.
— Include grant compliance responsiveness as part of employee performance evaluations
where applicable.
Paper-Based Operations
Critical aspects of MCSS' operations do not take advantage of available technology but rather rely
on paper. MCSS' paper processes appear to be inefficient and slow down the department's
workflow. MCSS has two offices —one in Key West and one in Key Largo and three congregate
meal sites located in Key West, Big Pine Key, and Key Largo. MCSS' personal care workers also
perform their work offsite in clients' homes. Automation would greatly benefit MCSS' processes
given the geographic dispersion the department faces with the work performed by staff.
One example of MCSS' reliance on paper is a key document used to identify what work a personal
care giver performs for a client in the home. As shown in Exhibit 2,the Weekly Homemaking Visit
— 9 —
Record is completed by the personal care worker for each client home visited. The worker will
identify the tasks performed and the time involved. The client is expected to sign the completed
form along with the employee and the employee's supervisor.
Exhibit 2
Example of Weekly Homemaking Visit Record
.�.�° ""
P w iL OMEMAKI I Ir et c R
a
6wptllNUi E COUNTY HOMEw n
� 'qY M
W
ARE
tlV 11714N q"rcMrflYugrt d�"Wl[sit 7C"�YNfdsit a"^�WIN
If lA4'�",
qq�B out p h ,liN qMf
1�9�MNWAb�'�
'yq'tTLN1E,3'p1 Ly
BgNGAd1+d , ��
,.m
......._ „.
S�XM'WG7Ce'W ......._...�.m.e ,
seRVIE
1...w. .ig. „�...... ,,.. ..�MONDAY
91A6q".AsaFWALur xunw5., ...��� —
U� ,ArM Not¢rawrnruu'a
-" .�... �,. ,_ �,..._._.
,MEDI�Itlk�dUMi,,,.,•, WWG aIM'#34Ch 41M
� Cxmnrc'�o�umax�wan..:
IPrc1A4�'F'R'1CIM'�dW�dGE
BED
dwVe�aua� rr�au�sra,��^
U�47>wIk�CSCM�rn sd'�mm s�"r�arcur�
LAUN A' �
IGGIMAIMd�!NU1"'�, �kt4YAE C2gILY�I�z
dust iQµ�nmusu
I�„�F '� ,"�Y'q, .'/�� �MfML I`Ad&'U✓41'ffi piiii ,
Aql@gq�IOsq°s ////
c me m��rru a q � I dwr fuUME ** ',ftkF
A � �
pan aav qAd a r� ns s �r ,xr .. a Aq � a��E l I V % %viz i�
�
IIII
Staff who complete a Weekly Homemaking Visit Record are expected to send the paper document
to MOSS' Key West Office where a designated staff person enters the data into the Florida
Department of Elder Affairs' (DOEA) statewide automated database known as the Enterprise
Client Information and Registration Tracking System (eCirts). Once weekly time records are
entered into eCirts, MCSS must generate reports from eCirts that are used to prepare and submit
grant reimbursement requests to the Alliance. Staff indicated during our interviews that it could
- 10 -
take a few days up to a few weeks before all the paper time records are received by the Key West
Office.
Because MCSS relies exclusively on paper time records,the Alliance demands to see all of MOSS'
time records to confirm staff's accuracy of entering the detail into eCirts. Whenever the Alliance
discovers a data entry error when doing their monitoring process, MCSS will receive an audit
finding.
Shortcomings of MOSS' reliance on paper time records when providing in-home services include:
• No documented confirmation that all personal care workers' in-home services are recorded
on a Weekly Homemaking Visit Record. Staff reported that MCSS management does not
maintain a centralized official work schedule for personal care staff assignments. If a client
needs in-home services, MCSS management communicates staff assignments either
verbally or via text message to a staff's personal cell phone. Staff reported that these official
communications are not maintained as official County records. Staff also reported that
personal care workers will talk amongst themselves to do self-scheduling without
management's direction or approval. Therefore, it is difficult, at any point in time, for the
County to know where personal care staff may be working.
• No internal controls exist that allows management to confirm that all personal care
workers' in-home services are entered into eCirts. As shown in Exhibit 2, the Weekly
Homemaking Visit Record is not a pre-numbered form that would allow tracking that all
time records completed were properly processed.
• No documentation exists that confirms that MCSS is reconciling data entered into eCirts
with the data recorded in the County's automated human resources/payroll system (known
as Workday). While the data recorded on the Weekly Homemaking Visit Record is entered
into eCirts, MCSS does not have an established process to ensure that similar data for the
employee is recorded in Workday. It is important that the staffing information entered into
eCirts for a grant reconciles to how an employee records their time for the same grant in
the County's payroll system to ensure that MCSS is requesting granting agencies to fund
the full amount being paid to an employee.
Many of the shortcomings could be addressed if MCSS were to automate its use of the time
records. One suggestion is to require personal care staff to use iPads to record their in-home time.
MCSS could investigate the possibility of integrating the automated time records for uploading to
eCirts as well as Workday. iPads also have the functionality that would allow management to
confirm a staff person's location at any given time.
— 11 —
We recommend that MCSS management evaluate all the department's paper-based processes
for automation to improve the department's efficiency, accountability, and effectiveness. MCSS
should investigate the possibility of integrating any automated solution with eCirts and Workday
to minimize data entry errors and ensuring all systems capture the same data.
Management Response:
MCSS agrees with this recommendation and will initiate a phased review and modernization of
all paper-based operations. We recognize that continued use of manual forms—such as the
Weekly Homemaking Visit Record—results in workflow delays, data entry errors, and limited
oversight. To address this, MCSS will pursue the following actions:
• Assess and Identify Automation Opportunities
— Conduct a full inventory of current paper-based forms and workflows (including
homemaking records, referrals, intake forms, and service logs).
— Prioritize the digitization of forms directly tied to grant compliance and payroll
reconciliation (e.g., time tracking, client service documentation).
• Implement a Digital Timekeeping and Service Logging Solution
— Pilot the use of Wads or mobile-enabled tablets for personal care workers to digitally
complete and submit service records in real-time.
— Evaluate digital tools with geo-location and e-signature capability to document service
delivery, client verification, and management review.
• Integrate Digital Records with Existing Systems
— Collaborate with Monroe County IT and relevant vendors to explore integrating
automated data entry into both:
eCIRTS, the DOEA database used for client tracking and reimbursement.
Workday, the County's payroll and human resources platform.
— Establish protocols to reconcile time entered into both systems and ensure grant-related
personnel costs are accurately documented and reimbursed.
• Establish Internal Controls and Oversight
— Explore introducing pre-numbered digital forms with submission tracking to ensure all
service records are accounted for.
— Develop a centralized scheduling and dispatch system to eliminate informal assignment
of client visits and improve transparency of field operations.
MCSS is committed to eliminating outdated paper-based practices and moving toward a fully
digital, mobile-enabled, and integrated service delivery model. We recognize that doing so will
enhance operational efficiency, improve compliance with grantor expectations, and strengthen
client outcomes.
— 12 —
Staffing Concerns
MCSS has total staffing of 56 full-time and part-time positions to assist clients throughout Monroe
County. In FY 2024, Monroe County Board of County Commissioners (BOCC) approved 14.59
FTE funded with ad valorem taxes. Given the multiple funding sources available to MOSS, it is
essential that MCSS proactively manage how staff's time are allocated among the department's
programs. Our review found that MCSS management is not attentive to how staff's time is funded
and appears to not be aware of how the department is structured or what positions are available
within the structure. In addition, the Senior Director of Social Services is allowing MCSS staff to
participate in the department's programs without ensuring proper oversight and approval.
During our interviews, staff expressed frustration over the department's organizational structure.
Specifically, staff expressed concern that the department's reporting structure appeared not to be
consistent with staff's job descriptions, and, as a result, created unnecessary conflict and confusion
among staff. Staff expressed concern that the organizational structure prohibited them from
performing their stated responsibilities as documented in their job description.
For example, according to Workday, there are three Senior Administrators: two Senior
Administrators for Operations (one located in Key West and the other in Key Largo); and one
Senior Administrator for Social Services located in Key West. All three positions are in the same
pay grade and have the same wording in their job descriptions as shown in Exhibit 3.
Exhibit 3
Excerpt from MOSS' Senior Administrator Job Description
MONROE COUNTY
JOB DESCRUTION
m .
Position Fide; SPU ADlwC1lwlf5°l i'l0F deports to:
(Social,Scrices Sr Director of s iai services
Position G! daaa �A~eta us:: Exempt tGlaaa,Cede: __
a� l�DEC Dbi
lie primary function of thhiis M,itiaan involves highly m9ponsilulim� the
arced administrative
Nutrition,and
pro ession l'
Work as well as derreal su rt.nis position involves cer7rdinat of Services, a'elfam,SHIP,,and other Co muunity suprpncurt services programs,7Cliis positrrrn includes aiding clients
and staff,supervising diem;intakes and assessments file reviews CIRTS data entry and review,and assistance
with review and conution of compliance:issues,Major r is onsibili"ties relate to Nuutritien activities, lease
include dealing waft daily operational issues,ChOnt assessnients,assisting wriO grvints and budgeting,and direct
supervision ofNutrition Sunnnn Ruffr
Both the Key Largo Senior Administrator of Operations and the Key West Senior Administrator
of Social Services supervise the in-home staff for their respective locations. However, contrary to
the wording in her job description,the Key West Senior Administrator of Operations has no actual
oversight/input into in-home services provided to clients.
— 13 —
Exhibit 4
MCSS Organization Hierarchy
a 0 a 0 Q
JNAM. Kii,i Wflk L I... EmiLmA. I,6la'd,11"
eri A", Ad,,,,,s,F—al n Ad Ad Ad': S","I in "'p"',r" Dlh,
J K I I CEk,h LK I I 1,1c,EW&,, I K)I�31111 IILII IJ,,,;K,!i, rW S—ic- I XII iatoB irg LK I I C,I,Eh,,iliFg ill1 II C.Itl FILW1311
MflaacLC,raaa2NDIP0001111 pl, "INEIPOSS 0ry"A P"u, CSCONOIU,II uq'd W"I
Ad, SpNh D;
Based on our review of the MCSS' positions and our follow-up with MCSS management, it also
appears that the Senior Director of Social Services lacks an overall awareness of the importance
of keeping MCSS' position descriptions accurate and position funding allocations up-to-date.
When asked about an unfilled Project Manager I position that shows in Workday as reporting
directly to her(see Exhibit 4),the Senior Director of Social Services replied she did not know that
the position existed and asked the auditors to provide her more information on this position.
We also found that MCSS management is not proactive in managing the department's positions
and, as a result, there has been an extended interruption in providing needed services to clients
under the WAP program. The purpose of the WAP program is to help income-qualified households
with energy efficient improvements to the home. The Senior Director of Social Services has opted
to rely on a single staff person to be a certified energy auditor who is responsible for completing
home inspections to analyze energy usage and identify conservation opportunities. The energy
auditor certification takes time to obtain.
MCSS hired a project manager in March 2024 who has been working diligently to achieve his
energy auditor certification. However, because MCSS staff are not cross-trained and no one else
in MCSS possesses the energy auditor certification nor has MCSS engaged a qualified consultant
to perform the energy auditor responsibilities in the interim, there has been delays in WAP clients
receiving their benefits.
— 14 —
Finally, staff discussed their concerns that the Senior Director of Social Services was allowing
MCSS staff to also be clients of the department's programs without ensuring proper oversight and
approval. For example, one of MOSS' on-call personal care workers applied to receive LIHEAP
benefits. Complicating this application is that the on-call personal care worker is also personally
employed by the Senior Director to perform childcare duties. Staff reported being uncomfortable
processing the personal care worker's LIHEAP application given the conflict of interest with her
employment in both MCSS and her outside employment with the Senior Director.
While the on-call personal care worker may qualify to receive LIHEAP benefits, the Senior
Director should have stepped aside and directed MCSS staff to work directly with the Senior
Director's supervisor and/or the County Administrator to assess the personal care worker's
LIHEAP application.
Given the number of staff and the multiple funding sources, it is critical that MCSS management
be diligent in managing the department's staff. To ensure effective department management, we
recommend MCSS work with the Office of Management and Budget and the Department of
Employees Services to:
• Develop an organization structure that provides clear lines of authority and supervision
for proper program and grant management;
• Verify position needs to properly manage department programs;
• Draft employee job descriptions that are not duplicative and properly reflect employees'
job duties and responsibilities;
• Develop a business plan that focuses on cross-training staff and establishing back-up
plans to ensure no interruption in client service during staff turnover, and
• Develop procedures that allow eligible MCSS staff to participate in MCSS program
offerings with oversight and sign-off provided by the County Administrator.
Management Response:
MCSS recognizes the importance of sound organizational structure, effective staffing oversight,
and a culture of accountability. We acknowledge the audits findings regarding deficiencies in
our current practices and are committed to making the necessary changes to ensure staff are
properly supported, programs are fully staffed and aligned with funding sources, and that
conflicts of interest are handled with appropriate oversight.
• MCSS agrees that the current organizational hierarchy needs revision. We will work in
partnership with the Monroe County Office of Management and Budget (OMB) and the
Department of Employee Services (DES)to:
- is -
Management Response(continued):
— Conduct a full assessment of the department's existing organizational chart and reporting
structure.
— Establish clear lines of authority that align with program responsibilities and job
descriptions.
— Ensure that all supervisory roles are properly assigned and communicated to staff.
• MCSS agrees that a full position and staffing audit is necessary. We will:
— Conduct a position control review in coordination with OMB and DES to confirm the
number,purpose, and funding of each position.
— Review and address vacant positions—such as the Project Manager 1—and determine
whether they should be reclassified, filled, or eliminated.
— Align positions with program needs, ensuring adequate staff coverage for all grant-
funded services.
• MCSS recognizes that unclear and duplicative job descriptions have created confusion and
conflict. We will:
— Work with DES to review and revise all MCSS job descriptions to reflect actual duties
and avoid overlap.
— Ensure consistency between job descriptions, organizational roles, and day-to-day
responsibilities.
— Provide training and clarification to staff on updated roles and responsibilities.
• MCSS agrees that staff cross-training and contingency planning are essential to avoid service
disruption. We will:
— Develop a department-wide business continuity plan that includes cross-training
priorities.
— Identify critical roles—such as the certified energy auditor—and establish internal or
external back-up options for program continuity.
— Include cross-training goals in annual staff development plans and performance reviews.
• MCSS acknowledges the importance of safeguarding against conflicts of interest when staff
apply for services. We will:
— Develop a formal written policy, in coordination with the County Administrator and
County Attorney's Office, outlining when and how MCSS staff may access department
services.
— Require County Administrator(or designee)approval and oversight for any staff member
receiving services, especially when a conflict of interest exists.
— Train all the program and intake staff on how to handle such cases appropriately and
transparently.
� 16 �
Financial Management and Budget Concerns
Our audit procedures included an examination of how MCSS maximized its grant funding. This
included reviewing MOSS' approved BOCC budgets for the audit period and evaluating the
timeliness and effectiveness of MOSS' oversight and management of their annual operating
budget. We also attempted to reconcile MOSS' approved budget to the actual revenues and
expenditures posted in the County's accounting records for the department's various grant
programs.
Our review found serious mismanagement of grant funds by MCSS management that appears to
have created a hidden budget shortfall for the County. The primary cause appears to be MCSS
regularly posting expenditures to expired grants. Additionally, it appears MCSS does not report
de-obligated grant funds to OMB in a timely manner,resulting in the failure to decrease the budget
in affected cost centers and allows overspending of budgets. We also found that MCSS
management is not properly prioritizing and managing its assistance programs to maximize the
County's grant funding resources.
Mismanagement of Grant Funds
Management of all of MOSS' multiple funding sources is an essential job function of the Senior
Director of Social Services. At the direction of the Senior Director, MCSS manages the budget for
each of its funding sources by working with OMB to create a cost center for each of its
programs/grant awards. Each cost center should have an approved annual budget based on MOSS'
projected funding for the respective fiscal year. One of the complicating factors that make MOSS'
Federal and state grant programs difficult to manage is that many of these grants are awarded on
budget cycles that do not align with the County's budget cycle.For example, an ADI grant's award
period is from July 1 to June 30 while the County's budget cycle is October 1 to September 30.
Likewise, an OAA grant award period is from January 1 to December 31. As a result, a cost center
designated for an ADI grant or an OAA grant will overlap two of the County's budget cycles as
illustrated in Table 1.
We reviewed how MCSS recorded revenues and expenditures to its various grant-related cost
centers during the three-year audit period. At the end of any grant award,the total of a cost center's
revenues (grant funds and applicable local match) should equal the total of a cost center's
expenditures.We found repeated instances where MOSS' grant-related cost centers did not balance
and/or had unusual or no activity. Table 2 provides examples of many of the problematic issues
we encountered when reviewing MOSS' fiscal management of all its grant programs.
— 17 —
Table 1
Example of Budgeting for ADI and OAA Grants
Cost Grant Award Grant Award County
Center Start Date End Date Fiscal Years
FY 2024
CC 6153624 07/01/2024 06/30/2025 (10/01/23—09/30/24)
ADI Grant FY 2025
(10/01/24—09/30/25)
CC_6154124 FY 2024
OAA Grant 01/01/2024 12/31/2024 (10/01/23—09/30/24)
III-CI FY 2025
(10/01/24—09/30/25)
A critical part of grants management is ensuring all grant-related expenditure match to grant-
related revenue. If this matching does not occur,then it is imperative for the County to find another
non-grant funding source for the expenditure. Table 2 provides examples where the cost center
did not balance at the end of the grant award period resulting in grant expenditures exceeding grant
revenue. For example, a shortfall occurred for cost center CC_6153622. Total expenditures over
the three fiscal years were $126,471 while matching revenue only totaled $84,559 resulting in a
$41,912 deficit.
Table 2
Review of ADI:Related Revenues and Expenditures For Audit Period
County County County
Funding Fiscal Year Fiscal Year Fiscal Year
.Available for 2022 2023 2024
Cost Center/ County
CramtAward Fiscal Years Revenues Expenditures Revenues Expenditures Revenues Expenditures
CC 6153621 Alzheu nefs
— F5'21 and FS'22 62.376.05 62,376.05 - 18,267.43 - 18,662.34
]Disease Iunitiative
CC 6153622 Alzhe�nner"s
FY J.'J-aulcflFY 23 16.3i6.52 16,3i6.t2 68,202.$2 99,$ 7.6$ - 10,256.99
]Disease Init'iat'ive
CC 61536'23 Alzflneiunner's
— FY 23 and FY 24 - - 21.253.'73 26,635 41 75,665.041 72.979.65
]Disease Initiative
CC G153G'2'4 Alzheimer"s
— F5"'4 and F5"'S - - - - 17,676.74 17,311.31
Disease Iniitiative
Other examples in Table 2 show similar discrepancies such as when MCSS posted expenditures
totaling $18,267 in FY 23 and $18,662 in FY 24 to an ADI-related cost center that was for a grant
award that ended on June 30, 2022. We reviewed the detail expenditures that were inappropriately
posted to an unavailable grant and found that the expenditures were for MCSS staff salaries and
fringe benefits. Because many of MCSS staff work on multiple grants as part of their job
responsibilities, MCSS establishes payroll costing allocations to allocate a staff person's salary
and related fringe benefits to individual grants based on the staff's expected work on the grant
- 18 -
programs. MCSS management is responsible for setting up, overseeing,reconciling, and updating
the payroll cost allocations.
When we asked staff the procedures for keeping payroll cost allocations current,we were told that
attempts are made by staff to keep these allocations updated. However, staff are unable to obtain
timely approval from the Senior Director of Social Services resulting in expired grant awards being
inappropriately charged for employees' salaries and fringe benefits. Because MOSS' payroll cost
allocations are not timely updated, MCSS is creating unfunded expenditures the County must now
find another funding source to finance these unmatched expenditures.
In addition to the above examples, MOSS' handling of the WAP grant demonstrates how the
department is not providing the required client services but continues to charge the grant for
unallowable expenditures. During the period October 2022 through June 2023, MCSS coded
$51,343.57 in staff salaries and fringe benefits to the WAP program. When closing out FY 2023,
MCSS told the Clerk's Office that a reimbursement request for the WAP grant was pending for
these expenditures and led the Clerk's Office to believe that an outstanding receivable should be
recorded at fiscal year-end. When no grant revenue was received in the subsequent fiscal year to
cover the expenditures, the Clerk's Office followed up with MOSS. After several attempts asking
for a status update, in August 2024 MCSS staff finally advised the Clerk's Office that MCSS
would not be receiving any WAP grant revenue to cover the $51,343.57. The reason MCSS was
not eligible to receive WAP funds is because it did not have the required certified energy auditor,
either on staff or contacted, that could perform the needed home assessments. MCSS did not have
any authorized budget to fund the $51,343.57 of expenditures.
The revenue shortfalls we noted during our audit period raised serious concerns about MOSS'
mismanagement of grants. Table 3 summarizes the total revenues and expenditures recorded in
the County's accounting system during the audit period. From this limited review, it appears that
MCSS fiscal mismanagement may have resulted in a material revenue deficiency for the County.
The actual deficit cannot be determined by the analysis performed in Table 3 because it is
important for the County to conduct a year-by-year review, going back beyond the three-year audit
period, to determine the actual revenue needed to cover unmatched grant expenditures. Once the
County is able to determine the financial impact of MOSS' grant mismanagement, it will be
necessary for revenue to be budgeted to fund any determined shortfalls.
� 19 �
Table 3
Reva iew of Grant Revenues and Expenditures for Audit Period
Grant Comity comah, County Three-Year
Prograin FY 22 FY 23 FY 24 IPeriod 'Total
0 A'A
Revenue S 6,60,419 $ 403n437 S 699...285 S 1...763,141
Expenditures, 858A05 L133387 132SA91 3.3210,283
Es,timated Revenue Shorfin 097,986) (729.,950) (1_557;142)
ADI
Revenue S 78,733 S9.-,457 S 93.-.342 S 261.532
]Expenditures, 7&733 144. 760 119,210 341703
Estirnated Revenue Shorfin - (25n868) (Slnl7l)
LIHEAP
Revenue S 259n872 $ 252,545 S 187n691 S 730.111
Expenditures, 261.139 282-548 291-734 835.421
Estirnated Revenue Shorfil (In267) - 004nO43), 0 0 5 n 3 10),
WAY
Revenue S 56,956 $ 9,433 S - S 66,389
Estirnated Revenue Shorfin 76.290 77.624 40391 194305
(19334) (68A91), (40391), (12-7,916),
Total Estimated
Revenue,Shortfall S (218,,587) S (S53,�444) (799,,508) (1,S71,,539)
To address MCSS' grant fiscal mismanagement, we recommend:
• A year-by-year review be performed of MCSS grants to verify that grant expenditure are
matched to actual grant revenue received and aplan be developed to properly fund any
unmatched grant expenditures.
• County Administration address the mishandling of MCSS grants including ensuring
staff are properly trained and MCSS management establish and adhere to policies and
procedures that ensure effective grant budget and fiscal management.
• County Administration work with granting agencies to ensure any appropriate corrective
actions are taken.
— 20 —
Management Response:
• MCSS leadership acknowledges the serious concerns raised in the audit regarding financial
mismanagement, particularly related to grant-funded programs and budget oversight. The
department accepts responsibility for the issues outlined and is committed to implementing
immediate corrective action in coordination with the Monroe County Office of Management
and Budget(OMB), the Clerk's Office, and external granting agencies.
We take the following audit findings seriously:
- Improper posting of expenditures to expired grants.
- Delayed reporting of de-obligated funds.
- Failure to reconcile payroll cost allocations in a timely manner.
- Unreimbursed expenditures being coded to grant cost centers without eligibility.
- Misleading reporting on grant reimbursement expectations.
These lapses have created unfunded liabilities for the County and weakened the financial
integrity of MCSS' operations. We are committed to full remediation and long-term
structural change.
• MCSS supports a full forensic review of grant cost centers to identify any unmatched
expenditures. We will:
- Collaborate with OMB and the Clerk's Office to conduct a detailed, year-by-year
reconciliation of grant revenues and expenditures, starting with the oldest open grants.
MCSS will seek assistance through a small contract with an outside CPA firm to assist
with this task.
- Flag all instances where salary/fringe or program costs were charged to expired or
ineligible grants.
- Develop a remediation plan that includes identifying and budgeting appropriate revenue
sources to cover any confirmed shortfalls necessary to make the governmental grant fund
whole.
• MCSS recognizes that significant gaps exist in our fiscal controls and internal approvals. To
correct this,we will:
- Begin the development of the internal grants management procedures for MCSS to
include tighter timelines for payroll cost allocation approvals, active grant monitoring,
and accurate close-out reporting.
- Require the Director of Community Services and key staff to complete formal training
in federal and state grant management, including Uniform Guidance (2 CFR Part 200).
- Designate a position within MCSS to assist with real-time budget tracking and ensure
expenditure posting accuracy.
- Establish a quarterly review process and report to validate grant balances and prevent
expired grants from being charged.
_ 21 —
Management Response(continued):
• MCSS will coordinate with all relevant granting agencies to:
— Request guidance and technical assistance on corrective action plans (CAP).
— Immediately work with grant agency to resolve any outstanding issues on previous
CAP's.
— Establish improved communication protocols to prevent future grant compliance issues.
Improper Approval and Budgeting of Grant Awards
Monroe County Administration Instruction (AI) 430 1.10 sets forth, ". . . the procedures that each
Department shall follow in submitting grant applications, in accounting for the use of federal and
state funds, including documenting staff time under all federal and state grants received by Monroe
County and in maintaining records for pre-audit and post-audit review . . ." in accordance with
applicable laws and regulations. In summary, the department head in conjunction with OMB, the
County Administrator, and the BOCC, determine the feasibility of submitting a grant application
on behalf of Monroe County. The BOCC adopted Resolution 267-2007 which authorizes the
County Administrator to manage grant application approvals, acceptance of awards and execute
grant-related documents when the grant does not have a local match requirement. Grants with a
match requirement must first receive BOCC approval before a department may submit a grant
application.
Once a grantor awards a grant to Monroe County, Al 4301.10 requires the grant award/contract
documents that have a local match requirement be placed on the BOCC's next monthly agenda for
the BOCC's review and approval. Once the BOCC approves the grant award/contract, the grant
award/contract must be sent to the County Attorneys' Office for processing and then routed to the
Clerk's Office for execution. Once executed,the department sends the signed grant award/contract
to the grantor. Concurrently, the department is expected to provide OMB with the grant budget.
We found MCSS management did not consistently adhere to established protocols for managing
grant applications and grant budgets. In fact, we identified issues were MCSS management
demonstrated a repeated pattern of not being forthcoming with budgetary information to allow
OMB to put forward proper annual grant budgets for BOCC approval. For example, it is MCSS'
responsibility to request OMB to create a new cost center when a new grant award is received. For
programs like OAA and ADI, this can result in multiple cost centers requiring budget within a
single county fiscal year. While MCSS notifies OMB when a cost center needs to be created, we
found that MCSS is not notifying OMB when a cost center should be de-activated allowing
unbudgeted expenditures.
Monroe County Administration Instruction 4301.10,Issued May 30,2019,Paragraph 2.
— 22 —
The active MCSS grant-related cost centers during FY 2024 totaled 33. Of these 33 active cost
centers, only 11 were for valid grant programs. By not de-activating cost centers when a grant
period has ended allows MCSS to mis-code grant-related expenditures. Coding grant expenditures
to expired grant awards prevents the County from seeking grant reimbursement from a grantor.
MCSS needs to work with OMB to proactively manage its cost centers.
Al 430 1.10 also requires MCSS to "ensure funds are only used for eligible grant activities within
the award period . . . If funds have to be de-obligated, coordination with OMB is critical."3 A
departments needs to keep OMB updated because it is not unusual for a change to a grant award
to have a budgetary impact. For example, the Florida Department of Commerce (Commerce) is
charged with allocating Federal LIHEAP funding statewide. To ensure that Florida uses all
available LIHEAP funds, Commerce continually monitors, estimates and re-estimates what
portion of the State's LIHEAP grant should be designated to specific grantees. If a grantee does
not appear to be on pace to use its full grant award, Commerce will de-obligate or reduce a portion
of the grant and reallocate it to another grantee. The WAP program is handled in a similar manner.
To communicate changes to funding levels, the State of Florida sends a Notice of Funding Award
(NFA) to grantees. An NFA will also be used to communicate other types of changes to a grant
such as changes to award periods.
We found repeated instances where an NFA was received by MCSS but not shared with OMB or
the BOCC in a timely manner and not sent to the Clerk's Office to include in the County's official
record. We found that when an NFA is received, MCSS oftentimes withholds this information. As
a result, OMB is not provided critical information to properly budget MOSS' grant awards and the
BOCC is not kept apprised of the County's funding.
One example of MCSS not sharing budget information with OMB and the BOCC is an NFA issued
by the then Florida Department of Economic Opportunity (now the Department of Commerce)
received in September 2023 for the LIHEAP grant. The September 2023 NFA awarded Monroe
County $358,127 effective July 1,2023,through Sepemteber 30,2024. A July 2024 NFA extended
the grant award through September 2025. OMB was not notified of either of these NFAs. A third
NFA was issued in September 2024, but it was not shared with OMB until November 2024. The
third NFA reduced the $358,127 grant award to $169,450 due to no grant expenditures being
reported. In November 2024, MCSS needed to notify OMB of this grant because they needed to
add funds to their operational budget.
When MCSS receives an NFA for the LIHEAP program, MCSS must report to Commerce how
the funds need will be budgeted. As shown in Exhibit 5, in November 2024, MCSS reported to
Commerce how they would spend the $169,450 grant.
3 Ibid.,Paragraph K.
— 23 —
Exhibit 5
November 2024 MCSS Budget Submission to DEO
NF,A#:42994 Revision Date: 11/1,12024
SUBRECIPIENTr.MDNRGECaUNTYSDClAL SERVICES AGREEMENTA E2012
"8-,�1, "o, ,- RPVVN��
SECDOM Ir&Aget Stunmary
Cu,l ujnin A Calumn 8 Calumn C.
LIHEAP FUNDS,ONLY C urrent 8 Age t Change to Line Total Revised
It— El ud,
Annount get,Annount
(A+B)
I LIHEAP FUNDS: $359.127.00 -$199.677.0,3 S165,4saw
I —
ADIVIIHISTRATIVEEXPENSE5
52126ES inCILdirg Fringe,Rant.Utilities,Travel,CthEr (Total cannot exceed
2 8.5%of Line 1;round down if needed.)" S30.440.00 S16.037.00 S14,403M
Selaries including Fringe,Rpnt�,Utilities,,Travel,Other(Total cannot exceed
3 15%of the difference between Line 1&Line 2)1 549.1S3.00 525.2,136.0D 523,257.00
MCXMILIM OUt�eCC EXDen3e: 1523,257.,GS
13,11RECTCLEENTASSISTANCE
HanneEnergyAwstance (Must beat least 25/of Line l:round upifneeded] 5IE5.000.00 -$95.OGO.00 Saw,ocaw
S42_162,SU
5 Crisis Assista,nce $EE.372.00 -$57,571.00 $29,401M
Weath,erRe,lated/5,up�pdy5,hrortage,/D�i&aster (Mustbeatleast2y.oflinel;
F, round up if needed.) 57.162.00 -53.773.0D 53,399M
7 TGTAL DIRECT CLI ENT ASSISTAN CE ILi r en 4+S+6 $279,534.Cri -$146,744.00 $131,750M
1 8 IGRANID Toi-AL ALL EXPENSES(Lines 2*347) $358,127.00 -$1,S8,E77.00 $169,450.00
After MCSS submitted its budget to Commerce, MCSS then emailed OMB to alert them that they
needed to increase their operational budget for the LIHEAP grant. While MCSS did not previously
share the September 2023 NFA with OMB, they did share the updated September 2024 NFA.
Exhibit 6 shows MCSS' email to OMB requesting that OMB submit a budget resolution for the
BOCC's approval. However, there are discrepancies between the budget summary MCSS
submitted to Commerce and the budget request sent to OMB. While MCSS advised Commerce
that they would budget$37,660 for salaries and fringe benefits, MCSS requested OMB budget the
full grant amount to utility payments. This type of inconsistency is commonplace and leads to the
confusion for effectively managing MCSS grant programs.
Exhibit 6
November 2024 MCSS Budget Request to OMB
NFA. 042984
LIHEAP grant
Contract period:7/1/23 to 9/30/25
Original award amount: $358,127.00 issued
Reduction amount: $-188,677.00 issued 9/24/24
New allocation:$169,450.00
CC# 125-6153517
Ledger-530430-SC-00'0'42 Home Energy Assistance$100,000.00
Ledger-530430-SC00'046 Utility Assistance amount$69,450.00
Please let me know if you have any questions,
Thank you again so much
— 24 —
Not only are there issues with ineffective management, MCSS appears to have difficulties
implementing new programs. For example, MCSS did not implement a new assistance program
for clients' water and sewer costs. Despite being formally awarded over $760,000 to support
Monroe County residents,the program was never launched. The Senior Director initially attributed
this failure to widespread issues with the program across the state. However, Miami-Dade County
reported receiving more than $19.7 million and successfully serving 17,234 customers. The Senior
Director later stated that difficulties arose in securing a signed vendor agreement with the Florida
Keys Aqueduct Authority (FKAA). However, when we did a follow-up inquiry to FKAA, the
FKAA stated that they never received a copy of the vendor agreement and had only been contacted
once via email regarding the program. The email the FKAA received from MCSS merely inquired
whether they had been informed of the program's existence. The result is that Monroe County
residents in need did not receive this aid. Rather,Monroe County's award was re-allocated to other
counties.
We recommend MCSS be directed to comply with all requirements ofAdministration Instruction
of 4301.10 including making any NFA received part of the BOCC's official record. We also
recommend OMB work with MCSS to establish formal procedures to ensure that MCSS cost
centers are for active grants only and cost centers are de-activated one a grant expires.
Management Response:
The Department acknowledges the findings presented regarding noncompliance with Monroe
County Administrative Instruction (AI) 4301.10 and the mismanagement of grant approvals,
NFAs, and related budget actions. The department accepts responsibility for these deficiencies
and is committed to correcting operational, procedural, and communication failures to ensure
compliance with County policy and fiscal responsibility.
MCSS will fully comply with Al 4301.10 going forward and has initiated the following steps:
A staff member will be tasked with ensuring all NFAs and grant modifications are
promptly submitted to OMB, the County Attorney, the Clerk's Office, and included on
the BOCC agenda when required.
NFA Tracker Implementation:An internal NFA tracking system is being developed to log receipt
dates, submission timelines, and key follow-up actions.
MCSS agrees that numerous cost centers were used after the expiration of the related grant,
which resulted in improper posting of expenditures and confusion in fiscal reporting. A full
review of active cost centers will be conducted to ensure that expired grants are closed out.
— 25 —
Management Response(continued):
Additionally, corrective measures include:
• Quarterly Cost Center Review: A new quarterly review process will ensure timely
creation and deactivation of cost centers aligned to grant cycles.
• Grant Close-Out Protocol:All grant close-outs will now trigger an automatic review of
the cost center's status. Cost centers will be deactivated within 30 days of the grant's
end date unless an extension is approved to account for an outstanding expense by the
department director.
• Develop Internal SOPS: Standard Operating Procedures for grant and budget
management to include required timelines and documentation for cost-center changes.
MCSS acknowledges the lack of internal coordination in preparing and transmitting accurate
budget information. To address this:
• Single Point Review: All budget submissions to external entities and internal County
departments must be reviewed and approved by the Community Services Director or
designee prior to submission.
• Budget narratives and financial forms submitted to grantors be matched against BOCC
budget requests and reviewed by OMB prior to any BOCC agenda approvals or budget
resolutions.
New Program Implementation: Failure to launch a fully funded water and sewer assistance
program valued at over $760,000, resulting in a reallocation of the grant to another agency
represents a significant operational failure.
A full internal review of this program will be conducted; the department will consider the
following actions:
• A formal vendor engagement protocol that includes documentation of all outreaches,
follow-up deadlines, and escalation procedures. MCSS will submit a quarterly
implementation status update for all new grant-funded programs to the Assistant
County Administrator.
SHIP Program Oversight
The State Housing Initiative Program (SHIP) Partnership is governed by Florida Statute and
provides funding to support local affordable housing initiatives. Florida Housing Finance
Corporation (FHFC) administers the SHIP program at the state-level and allocates these grant
funds to Monroe County. Eligible clients may receive financial assistance through several
programs, including down payment assistance, home rehabilitation grants, zero-interest deferred
— 26 —
loans, and loans for rental housing development and construction. These financial benefits are
designed to make housing more accessible and sustainable for low and moderate-income
households.
To ensure compliance with Florida law and continued access to SHIP funding, Monroe County
must submit various reports. The Annual Report, detailing the use of SHIP funds, must be
submitted to the FHFC by September 15 of each year. Additionally,the Local Housing Assistance
Plan (LHAP), which is tailored to address Monroe County's specific housing needs, is required
every three years, though amendments can be made as needed. Another critical compliance
requirement is the Affordable Housing Advisory Committee (AHAC) recommendations, which
are mandated under Florida Statute. We were not provided any evidence that MCSS submitted the
required annual reports to the State on a timely basis.
The AHAC plays a vital role in the shaping of the County's local housing policies. The AHAC
focuses on making recommendations for incentive strategies that promote affordable housing
development. Since its establishment in 2008, the County's Planning Department has staffed
AHAC, ensuring compliance with state statutes. However, in 2018, MCSS assumed responsibility
of being the SHIP Administrator, which was previously managed by Monroe County Housing
Authority. The allocation of SHIP funding by the State is directly tied to compliance with the
Annual Reports, LHAP guidelines, and AHAC recommendations.
Although engagement with AHAC is a requirement for SHIP funding, MCSS has not participated
in the committee's activities until recently. In March 2025, after being encouraged by the County
Attorney's Office, MCSS increased its involvement in AHAC. While the Planning Department
remains well-positioned to lead AHAC, Florida statutes specify that the committee should be
cooperatively staffed with the Planning and Housing programs to ensure an integrated approach to
affordable housing solutions.
We recommend County Administration establish a formalized process for AHAC meetings to
ensure MCSS works cooperatively with the AHAC committee as well as oversee the
requirements of the committee to ensure compliance with state statutes and program
compliance.
We recommend MCSS define roles and responsibilities for the SHIP program, incorporating
compliance measures to ensure proper oversight of SHIP requirements.
— 27 —
Management Response:
MCSS acknowledges the serious implications of noncompliance with SHIP requirements and
the potential threat to the County's access to affordable housing funding. The department is fully
committed to meeting all state reporting deadlines, actively supporting the AHAC committee,
and ensuring that SHIP program responsibilities are clear, enforced, and integrated across
departments. Through these reforms, Monroe County will continue to deliver vital housing
support to low and moderate-income residents while maintaining full compliance with state law
and FHFC expectations.
MCSS will correct its delayed engagement with the following actions:
— MCSS staff will regularly attend AHAC meetings and are responsible for contributing
updates on SHIP-funded initiatives,needs assessments,and coordination with the LHAP.
— MCSS will coordinate with the Planning Department to ensure AHAC's operations are
jointly supported, aligning with Florida Statutes and encouraging a strong housing
strategy.
MCSS will develop a SHIP Program Oversight Framework that clearly outlines the
responsibilities of staff involved including responsibility for program oversight, monitoring
compliance, and inter-departmental coordination. Financial tracking, reporting, and
reconciliation of SHIP funds. LHAP drafting and approval, community engagement, and
coordination with AHAC and FHFC.
Management Response:
Conclusion:
MCSS recognizes that its failures in grant management, communication, and program
implementation have contributed to fiscal confusion, missed funding opportunities, and a loss
of public trust. We are fully committed to complying with Monroe County administrative
policies and ensuring that all future grant activities are conducted transparently, accurately, and
in the best interests of the residents we serve.
— 28 —