2022-001 Procurement Policy Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Agriculture Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Award Number and Year: 222MN101S2514; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations ? 200.318 states that the non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform with applicable federal law and the standards identified in this regulation. Condition: MNPrairie?s written procurement policies do not have all the required components of a procurement policy in accordance with Title 2 U.S. Code of Federal Regulations ? 200.318. Questioned Costs: None. Context: This issue was discovered during the audit of the major federal program; however, it impacts federal programs entity-wide. Written policies that reflect the specific components of federal regulations improve controls to ensure compliance with federal award requirements. Effect: Written policies and procedures that are not updated to reflect the Uniform Guidance procurement requirements could increase the risk of noncompliance with federal program requirements. Cause: MNPrairie management indicated they were not able to complete an update to the policy in 2022, but it is an ongoing project. Recommendation: We recommend MNPrairie implement and adhere to written procurement policies addressing the specific components of the Uniform Guidance requirements. View of Responsible Official: Acknowledge.
2022-002 Procurement Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Agriculture Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Award Number and Year: 222MN101S2514; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations ? 200.318(i) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Of the five procurement transactions tested for compliance with federal regulations, three instances were noted where the history of the procurement was not documented. Additionally, for two procurements tested, there was no documentation of full and open competition. Questioned Costs: None. Context: Five of 30 small purchase procurements were tested for compliance with applicable federal regulations. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: MNPrairie is not in compliance with federal regulations. Cause: Processes have not been implemented to ensure that required procurement documentation is prepared in accordance with federal regulations and the procurement policy. Recommendation: We recommend MNPrairie document the history of procurement transactions including full and open competition in accordance with federal regulations. View of Responsible Official: Acknowledge.
2022-003 Eligibility Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.558 Temporary Assistance for Needy Families Award Number and Year: 2201MNTANF; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 42 U.S. Code of Federal Regulations ? 602(a)(1)(B)(iii) requires each state to create a written document that sets forth the objective criteria for the delivery of benefits and the determination of eligibility. The Minnesota Department of Human Services? State Plan for Temporary Assistance for Needy Families (TANF) and Minn. Stat. ? 256J.10 establish the general eligibility requirements for TANF benefits. Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by MNPrairie to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation was available, updated, or input correctly to support participant eligibility. The following exceptions were noted in the sample of 40 MAXIS case files tested: ? One case file viewed included child support income which was not supported by documentation on file. ? Four case files viewed either did not have updated asset amounts or the asset amounts listed were not supported by documentation on file. Questioned Costs: None. Context: The State of Minnesota and MNPrairie split the eligibility determination process. Pursuant to Minnesota statutes, MNPrairie performs the ?intake function? needed for this program, while the State maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the State. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The lack of updated information in MAXIS documenting verification of key eligibility-determining factors increases the risk that a program participant will receive benefits when they are not eligible. Cause: Program personnel entering case data into MAXIS did not ensure all required information was input correctly or was supported and that all required information was obtained and/or retained. Recommendation: We recommend MNPrairie implement additional procedures to provide reasonable assurance that all necessary documentation to support eligibility determinations exists, the information is properly input or updated in MAXIS, and issues are followed up on in a timely manner. In addition, consideration should be given to providing further training to program personnel. View of Responsible Official: Acknowledge.
2022-004 Child Support Non-Cooperation Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.558 Temporary Assistance for Needy Families Award Number and Year: 2201MNTANF; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 45 U.S. Code of Federal Regulations ? 264.30 states: ?What procedures exist to ensure cooperation with the child support enforcement requirements? (a) (1) The State agency must refer all appropriate individuals in the family of a child, for whom paternity has not been established or for whom a child support order needs to be established, modified or enforced, to the child support enforcement agency (i.e., the IV-D agency). (2) Referred individuals must cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for a good cause or other exception established by the State agency responsible for making good cause determinations in accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with ? 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency must then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family of the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the family any assistance under the program." Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by MNPrairie to support the eligibility determination process. Part of the eligibility determination process is cooperating with child support requirements. When a case is in child support non-cooperation status, per the IV-D agency, MNPrairie must reduce benefits. In a sample of 15 case files reviewed, two case files had identified errors related to improper reduction of benefits or improper timing of reduced benefits for case files in non-cooperation status. Questioned Costs: None. Context: Child support non-cooperation is determined by MNPrairie, and the Providing Resources to Improve Support in Minnesota (PRISM) system maintains the information and recipient status. When a Child Support Officer at MNPrairie updates PRISM to show non-cooperation, it interfaces with MAXIS. From this interface, MAXIS receives a Worker?s Daily Report (DAIL) message which notifies the entity of child support non-cooperation. MNPrairie is responsible for updating the recipient?s record in MAXIS, including entering child support sanctions, or closing a case on the seventh occurrence of noncompliance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Noncompliance with Title 45 U.S. Code of Federal Regulations ? 264.30. Benefit overpayments could be paid when child support non-cooperation is not properly processed for a benefit month. Cause: Program personnel entering case data into MAXIS overlooked reducing the benefits for the child support non-cooperation cases identified. Recommendation: We recommend MNPrairie review its guidance for child support non-cooperation to ensure benefits are being reduced as necessary in MAXIS. View of Responsible Official: Acknowledge.
2022-001 Procurement Policy Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Agriculture Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Award Number and Year: 222MN101S2514; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations ? 200.318 states that the non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform with applicable federal law and the standards identified in this regulation. Condition: MNPrairie?s written procurement policies do not have all the required components of a procurement policy in accordance with Title 2 U.S. Code of Federal Regulations ? 200.318. Questioned Costs: None. Context: This issue was discovered during the audit of the major federal program; however, it impacts federal programs entity-wide. Written policies that reflect the specific components of federal regulations improve controls to ensure compliance with federal award requirements. Effect: Written policies and procedures that are not updated to reflect the Uniform Guidance procurement requirements could increase the risk of noncompliance with federal program requirements. Cause: MNPrairie management indicated they were not able to complete an update to the policy in 2022, but it is an ongoing project. Recommendation: We recommend MNPrairie implement and adhere to written procurement policies addressing the specific components of the Uniform Guidance requirements. View of Responsible Official: Acknowledge.
2022-002 Procurement Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Agriculture Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Award Number and Year: 222MN101S2514; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations ? 200.318(i) states that the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: Of the five procurement transactions tested for compliance with federal regulations, three instances were noted where the history of the procurement was not documented. Additionally, for two procurements tested, there was no documentation of full and open competition. Questioned Costs: None. Context: Five of 30 small purchase procurements were tested for compliance with applicable federal regulations. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: MNPrairie is not in compliance with federal regulations. Cause: Processes have not been implemented to ensure that required procurement documentation is prepared in accordance with federal regulations and the procurement policy. Recommendation: We recommend MNPrairie document the history of procurement transactions including full and open competition in accordance with federal regulations. View of Responsible Official: Acknowledge.
2022-003 Eligibility Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.558 Temporary Assistance for Needy Families Award Number and Year: 2201MNTANF; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 42 U.S. Code of Federal Regulations ? 602(a)(1)(B)(iii) requires each state to create a written document that sets forth the objective criteria for the delivery of benefits and the determination of eligibility. The Minnesota Department of Human Services? State Plan for Temporary Assistance for Needy Families (TANF) and Minn. Stat. ? 256J.10 establish the general eligibility requirements for TANF benefits. Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by MNPrairie to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation was available, updated, or input correctly to support participant eligibility. The following exceptions were noted in the sample of 40 MAXIS case files tested: ? One case file viewed included child support income which was not supported by documentation on file. ? Four case files viewed either did not have updated asset amounts or the asset amounts listed were not supported by documentation on file. Questioned Costs: None. Context: The State of Minnesota and MNPrairie split the eligibility determination process. Pursuant to Minnesota statutes, MNPrairie performs the ?intake function? needed for this program, while the State maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the State. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The lack of updated information in MAXIS documenting verification of key eligibility-determining factors increases the risk that a program participant will receive benefits when they are not eligible. Cause: Program personnel entering case data into MAXIS did not ensure all required information was input correctly or was supported and that all required information was obtained and/or retained. Recommendation: We recommend MNPrairie implement additional procedures to provide reasonable assurance that all necessary documentation to support eligibility determinations exists, the information is properly input or updated in MAXIS, and issues are followed up on in a timely manner. In addition, consideration should be given to providing further training to program personnel. View of Responsible Official: Acknowledge.
2022-004 Child Support Non-Cooperation Prior Year Finding Number: N/A Repeat Finding Since: N/A Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.558 Temporary Assistance for Needy Families Award Number and Year: 2201MNTANF; 2022 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 45 U.S. Code of Federal Regulations ? 264.30 states: ?What procedures exist to ensure cooperation with the child support enforcement requirements? (a) (1) The State agency must refer all appropriate individuals in the family of a child, for whom paternity has not been established or for whom a child support order needs to be established, modified or enforced, to the child support enforcement agency (i.e., the IV-D agency). (2) Referred individuals must cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for a good cause or other exception established by the State agency responsible for making good cause determinations in accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with ? 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency must then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family of the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the family any assistance under the program." Condition: The Minnesota Department of Human Services maintains the computer system, MAXIS, which is used by MNPrairie to support the eligibility determination process. Part of the eligibility determination process is cooperating with child support requirements. When a case is in child support non-cooperation status, per the IV-D agency, MNPrairie must reduce benefits. In a sample of 15 case files reviewed, two case files had identified errors related to improper reduction of benefits or improper timing of reduced benefits for case files in non-cooperation status. Questioned Costs: None. Context: Child support non-cooperation is determined by MNPrairie, and the Providing Resources to Improve Support in Minnesota (PRISM) system maintains the information and recipient status. When a Child Support Officer at MNPrairie updates PRISM to show non-cooperation, it interfaces with MAXIS. From this interface, MAXIS receives a Worker?s Daily Report (DAIL) message which notifies the entity of child support non-cooperation. MNPrairie is responsible for updating the recipient?s record in MAXIS, including entering child support sanctions, or closing a case on the seventh occurrence of noncompliance. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Noncompliance with Title 45 U.S. Code of Federal Regulations ? 264.30. Benefit overpayments could be paid when child support non-cooperation is not properly processed for a benefit month. Cause: Program personnel entering case data into MAXIS overlooked reducing the benefits for the child support non-cooperation cases identified. Recommendation: We recommend MNPrairie review its guidance for child support non-cooperation to ensure benefits are being reduced as necessary in MAXIS. View of Responsible Official: Acknowledge.