Audit Report on the Human Resources Administration’s WeCARE Contract With Arbor Education and Training

This audit determined whether Arbor Education and Training (Arbor) is complying with certain key financial, programmatic, and administrative provisions of its Wellness, Comprehensive Assessment, Rehabilitation, and Employment (WeCARE) contract with the Human Resources Administration (HRA). The primary scope of the audit was Fiscal Year 2009 (July 1, 2008 through June 30, 2009).

HRA is responsible for helping individuals and families achieve and sustain their maximum degree of self-sufficiency. In Fiscal Year 2005, HRA developed the WeCARE program, which is intended to improve the employability of clients with health and/or mental barriers to employment. Through case management, job training, and employment placement services, HRA’s contractors strive to assist participants achieve self sufficiency.

WeCARE services are provided by two outside contractors: Federation Employment and Guidance Service (FEGS) and Arbor. This audit focuses on Arbor’s compliance with the terms of the WeCARE contract it signed with HRA. The total payments made by HRA to Arbor in Fiscal Year 2009 amounted to $33,295,170.

Audit Findings and Conclusions

Arbor generally complied with most of the key provisions reviewed for this audit, but improvements are needed in some areas. Arbor developed a quality improvement plan and a comprehensive set of operating procedures to help ensure compliance with the WeCARE contract and to improve the quality of its client services. Arbor’s job-retention milestone claims that we reviewed were generally supported adequately. In addition, the physicians we reviewed that Arbor used to evaluate clients were properly licensed and registered.

However, Arbor was only in partial compliance with some of the provisions of its WeCARE contract with HRA. The partial compliance primarily related to Arbor not adequately ensuring that its non-job-retention milestone claims were accurate and that its program staff met established qualifications. Arbor also did not closely monitor client attendance as required or comply with the contract’s provision concerning the hiring of former cash-assistance recipients.
HRA has implemented oversight techniques through its Customized Assistance Services (CAS) unit, such as holding regular meetings with Arbor officials and having HRA employees stationed at Arbor who regularly works with Arbor on issues relating to clients’ participation in the WeCARE program. HRA has also developed a program monitoring system through the New York County Health Services Review Organization (NYCHSRO), its outside contractor. However, the audit concluded that HRA’s oversight of the contract could be improved in certain areas. HRA did not maintain adequate records of its monitoring meetings with Arbor and did not ensure that Arbor had adequate supporting documentation for its non-job-retention milestone claims. In addition, HRA needs to review the reasonableness of the contract’s hiring provision, revise it as necessary, and then ensure contractor compliance.

Audit Recommendations

To address these issues, the audit recommends, among other things, that Arbor:

• Ensure that its non-job-related milestone claims are properly supported before they are submitted.
• Ensure that employees providing WeCARE services have the proper qualifications and experience required by the contract.
• More closely monitor client attendance.
• Comply with the hiring commitment provision of the contract or request exemptions on a timely basis.

To address these issues, the audit also recommends, among other things, that HRA:

• Prepare records of the results of its monitoring meetings with Arbor and share the meeting records with Arbor.
• Implement a process to review non-job-retention milestone payments to ensure that these milestones are properly supported before they are paid.
• Assess the reasonableness of the hiring commitment provision, revise it as necessary, and then ensure contractor compliance. HRA should consider establishing hiring goals at the start of each fiscal year and then evaluating the contractor’s efforts to meet those goals at the end of each fiscal year.

Agency Response

HRA provided the responses to all of the recommendations, including those addressed to Arbor. In their response, HRA officials agreed with five recommendations, partially agreed with two, and disagreed with seven.