U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Treasury
Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Significant Deficiency, Nonmaterial Noncompliance - Procurement
Finding 2023-003
Criteria or Specific Requirement: Per Section 200.318 of the Uniform Grant Guidance, a non-federal entity must use documented procurement procedures for the acquisition of services required under a federal or State award.
Condition: There was one instance out of 11 contracts tested where the County did not properly follow the Uniform Grant Guidance procurement standards for contracted services.
Questioned Costs: None.
Effect: By not having the required documentation in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds.
Cause: The County utilized an existing vendor contract that had not been previously procured in accordance with the Uniform Grant Guidance procurement standards.
Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts or at least ensure that when utilizing a previously issued contract, the necessary procurement standards are met or completed prior to utilizing the vendors contract for a federal or State grant.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Treasury
Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Significant Deficiency, Nonmaterial Noncompliance - Procurement
Finding 2023-003
Criteria or Specific Requirement: Per Section 200.318 of the Uniform Grant Guidance, a non-federal entity must use documented procurement procedures for the acquisition of services required under a federal or State award.
Condition: There was one instance out of 11 contracts tested where the County did not properly follow the Uniform Grant Guidance procurement standards for contracted services.
Questioned Costs: None.
Effect: By not having the required documentation in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds.
Cause: The County utilized an existing vendor contract that had not been previously procured in accordance with the Uniform Grant Guidance procurement standards.
Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts or at least ensure that when utilizing a previously issued contract, the necessary procurement standards are met or completed prior to utilizing the vendors contract for a federal or State grant.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: North Carolina Department of Health and Human Services
Program Name: Medical Assistance
Federal Assistance Listing Number: 93.778
Material Weakness and Non-Material Non-Compliance – Eligibility
Finding 2023-002 – Repeat Finding
Criteria or specific requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
The County should have adequate documentation for each participant that supports each eligibility determination and the information entered into NCFAST. We noted several errors related to the following compliance criteria:
a) The caseworker should prepare and submit a DMA-5097 form in the case of noncooperation as described in the Eligibility Review Document.
b) When the Social Security Administration (SSA) terminates social security income (“SSI”) eligibility, the county is required to make an ex-parte determination for eligibility. This determination is required to be made within 120 days after the termination of the SSI payment.
c) An OVS inquiry must be completed and agreed to information reported in NC FAST.
d) An AVS inquiry must be completed and agreed to information reported in NC FAST.
e) When forcing eligibility, documentation explaining the reasoning for the forced eligibility is required to be maintained on file.
Condition: The following are the results of non-material non-compliance noted for each criteria listed above out of the 122 program participants selected for testing:
a) There were two instances where the non-cooperation with IV-D was identified but no DMA-5097 was sent.
b) There were two instances where the County did not complete the ex-parte review for a participant whose SSI benefits were terminated during the year. The County should have forced eligibility, due to the COVID-19 exemption, but did not force eligibility for these instances.
c) There was one instance where the County did force eligibility, but they forced it to the wrong program.
d) There was one instance where the resources found through the register of deeds did not agree to the resources in NC FAST which affected the countable resource calculation.
e) There were two instances where the OVS query was not run at the time of the determination.
f) There were two instances where eligibility was forced but no documentation explaining the reasoning for was documented at the time of the determination.
Lastly, there were 31 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely.
Context: There were 9 out of 122 unique participants tested with the errors noted above, in which one was determined to have been improperly determined eligible.
Questioned Costs: We noted a total of $59,534 in questioned costs related to improper eligibility determination related to item “b” above. Total claims tested totaled $6,913,895 and so the projected questioned costs were at a calculated 0.86% error rate.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible.
Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis.
Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Treasury
Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Significant Deficiency, Nonmaterial Noncompliance - Procurement
Finding 2023-003
Criteria or Specific Requirement: Per Section 200.318 of the Uniform Grant Guidance, a non-federal entity must use documented procurement procedures for the acquisition of services required under a federal or State award.
Condition: There was one instance out of 11 contracts tested where the County did not properly follow the Uniform Grant Guidance procurement standards for contracted services.
Questioned Costs: None.
Effect: By not having the required documentation in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds.
Cause: The County utilized an existing vendor contract that had not been previously procured in accordance with the Uniform Grant Guidance procurement standards.
Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts or at least ensure that when utilizing a previously issued contract, the necessary procurement standards are met or completed prior to utilizing the vendors contract for a federal or State grant.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Treasury
Program Name: Coronavirus State and Local Fiscal Recovery Funds
Federal Assistance Listing Number: 21.027
Significant Deficiency, Nonmaterial Noncompliance - Procurement
Finding 2023-003
Criteria or Specific Requirement: Per Section 200.318 of the Uniform Grant Guidance, a non-federal entity must use documented procurement procedures for the acquisition of services required under a federal or State award.
Condition: There was one instance out of 11 contracts tested where the County did not properly follow the Uniform Grant Guidance procurement standards for contracted services.
Questioned Costs: None.
Effect: By not having the required documentation in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds.
Cause: The County utilized an existing vendor contract that had not been previously procured in accordance with the Uniform Grant Guidance procurement standards.
Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts or at least ensure that when utilizing a previously issued contract, the necessary procurement standards are met or completed prior to utilizing the vendors contract for a federal or State grant.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
Department of Housing and Urban Development
Program Name: Continuum of Care Program
Federal Assistance Listing Number: 14.267
Material Weakness, Non-Material Non-Compliance – Special Test – Reasonable Rental Rates
Finding 2023-004
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: There were 37 instances out of 40 program participants tested where evidence of a secondary reviewer of the eligibility determination was not retained.
Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Additionally, without retaining evidence a person other than the prepared reviewed the eligibility determination, the County will not be able to evidence such control to a third party.
Questioned Costs: None.
Cause: The County did not have a formal policy to document the review process for eligibility determinations and a process to ensure they were being completed and retained.
Recommendation: We recommend the County document and follow its policies regarding eligibility determinations and ensure all documentation is included in the file prior to final approval.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.
U.S. Department of Health and Human Services
Pass-through Entity: N.C. Department of Health and Human Services
Program Name: Foster Care and Adoption
Federal Assistance Listing Number 93.658 and 93.659
Significant Deficiency; Non-Material Non-Compliance – Allowability and Eligibility
Finding 2023-005
Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Condition: For one of the 40 participants selected, an amount of $1,004 was requested for reimbursement that was not paid to the third party facility.
Questioned Costs: $1,004 of known questioned costs and $90,594 of likely questioned costs.
Effect: By not having the required documentation in the files to support payment for costs recorded, the County may request reimbursement for costs not incurred.
Cause: County oversight when performing reviews over payment reimbursements.
Recommendation: We recommend the County implement a procedure to ensure all costs being requested within reimbursements have been incurred by the County prior to requesting reimbursement.
Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan.
Corrective Action Plan: See Corrective Action Plan prepared by the County.