Audit 15529

45 C.F.R. Section 260.31 contains guidelines that address eligibility for TANF assistance. In general, in order to be eligible, a family must include a minor child who lives with a parent or other adult caretaker relative. The child must be less than 18 years old, or, if a full-time student in a secondary school (or the equivalent level of vocational or technical training), less than 19 years old. A family must be determined to be "needy" according to the State's applicable income and resource criteria. Ohio Administrative Code Rule 5101:14-1-05 A(2) states, "For CCMEP (Comprehensive Case Management and Employment Program) participants not in receipt of OWF, the lead agency shall utilize the JFS 03000 "CCMEP TANF Eligibility Review Application" to conduct the annual review process to ensure that a program participant that is receiving temporary assistance for needy families (TANF) funded services and that is not receiving OWF meets the eligibility criteria described in paragraph (B)(2) of rule 5101:14-1-04 of the Administrative Code." We found that for one, or 4%, of the CCMEP expenditures tested, Harrison County DJFS did not timely recertify a CCMEP participant and therefore did not maintain a CCMEP TANF Eligibility Review Application within the participant's case file. The County did not have a process in place to ensure their CCMEP participant case files contained timely CCMEP TANF recertifications or income verification documents. The inability to timely recertify CCMEP participants and maintain applications and appropriate supporting documentation results in eligibility not being able to be verified. This could result in ineligible individuals receiving program funds, which could lead to possible questioned costs and jeopardize future federal funding. The Harrison County Department of Job and Family Services should ensure that all CCMEP TANF recertification applications, as well as any documents needed to verify information provided on the application, are timely completed, and properly retained in the participant's case file.

2 CFR § 200.331 requires a pass-through entity to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibilities for the Federal award. During 2022, the Harrison County Department of Job and Family Services (HCDJFS) contracted with a subrecipient to provide services related to its Comprehensive Case Management Employment Program (CCMEP) of the Temporary Assistance for Needy Families (TANF) federal grant. The HCDJFS did not perform necessary monitoring procedures under the Uniform Guidance over this subrecipient. The Harrison County Department of Job and Family Services should review the Uniform Guidance in 2 CFR part 200, which lists its responsibilities as a pass-through entity, establish and maintain its own internal control procedures over compliance with grant requirements, and create a subrecipient monitoring policy to meet the Uniform Guidance audit requirements. The HCDJFS should also document its subrecipient monitoring controls and reviews, and maintain the documentation over the monitoring over its subrecipient.

45 C.F.R. Section 260.31 contains guidelines that address eligibility for TANF assistance. In general, in order to be eligible, a family must include a minor child who lives with a parent or other adult caretaker relative. The child must be less than 18 years old, or, if a full-time student in a secondary school (or the equivalent level of vocational or technical training), less than 19 years old. A family must be determined to be "needy" according to the State's applicable income and resource criteria. Ohio Administrative Code Rule 5101:14-1-05 A(2) states, "For CCMEP (Comprehensive Case Management and Employment Program) participants not in receipt of OWF, the lead agency shall utilize the JFS 03000 "CCMEP TANF Eligibility Review Application" to conduct the annual review process to ensure that a program participant that is receiving temporary assistance for needy families (TANF) funded services and that is not receiving OWF meets the eligibility criteria described in paragraph (B)(2) of rule 5101:14-1-04 of the Administrative Code." We found that for one, or 4%, of the CCMEP expenditures tested, Harrison County DJFS did not timely recertify a CCMEP participant and therefore did not maintain a CCMEP TANF Eligibility Review Application within the participant's case file. The County did not have a process in place to ensure their CCMEP participant case files contained timely CCMEP TANF recertifications or income verification documents. The inability to timely recertify CCMEP participants and maintain applications and appropriate supporting documentation results in eligibility not being able to be verified. This could result in ineligible individuals receiving program funds, which could lead to possible questioned costs and jeopardize future federal funding. The Harrison County Department of Job and Family Services should ensure that all CCMEP TANF recertification applications, as well as any documents needed to verify information provided on the application, are timely completed, and properly retained in the participant's case file.

2 CFR § 200.331 requires a pass-through entity to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibilities for the Federal award. During 2022, the Harrison County Department of Job and Family Services (HCDJFS) contracted with a subrecipient to provide services related to its Comprehensive Case Management Employment Program (CCMEP) of the Temporary Assistance for Needy Families (TANF) federal grant. The HCDJFS did not perform necessary monitoring procedures under the Uniform Guidance over this subrecipient. The Harrison County Department of Job and Family Services should review the Uniform Guidance in 2 CFR part 200, which lists its responsibilities as a pass-through entity, establish and maintain its own internal control procedures over compliance with grant requirements, and create a subrecipient monitoring policy to meet the Uniform Guidance audit requirements. The HCDJFS should also document its subrecipient monitoring controls and reviews, and maintain the documentation over the monitoring over its subrecipient.