Audit 293988

Criteria: The Department is required to identity in its annual plan the population eligible for NAP benefits, In testing the propriety of eligibility determinations and disbursements for NAP benefits, the auditor shall apply the eligibility criteria established by the Department and identified in the annual plan (7 CFR section 285.3(b)(2)). 7 CFR Part 285 Section 3 - Plan of Operation. states (b) the plan of operation shall include the following, information: ( 2) A description of the needy persons residing in the Commonwealth of Puerto Rico and an assessment of the food and nutrition needs of these persons, The description and assessment shall demonstrate that the Nutrition Assistance Program is directed toward the neediest persons in the Commonwealth of Puerto Rico. We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participantlbeneficiary was eligible. as required by the Department procedures and federal law. As a result. we could not conclude participants reviewed were eligible to receive benefits as required by the federal award. Perspective We selected a sample of forty (40) participant files as part of compliance testing regarding eligibility. Auditors noted several cases in which the following documentation was not present in participants' tiles as follows: • (2) Verification of valid ID • (2) Evidence of residence • (3) Release of information form • (2) USA Citizenship or Verification of Alien Status form • (2) No copy of Social Security ID or SAID.' verification form of participants • (2) Resource Verification Form ($5k-$15k) • (2) Determination form • (2) Notification Advice form The above documentation is required as part of the eligibility controls established in the program's state plan to prove the existence of participants. Effect: The Department may be qualifying participants who do not meet the eligibility requirements established by federal regulations. T his may ultimately result in sanctions, reduced funding. having to return monies to the federal agency. or cancellation of grants. Cause: The Department is not adhering to the established internal control procedures and not adequately documenting its evaluation and conclusion over the eligibility of participants. Recommendation: The Department must adhere to its existing internal control procedures to properly document eligibility verification procedures performed and to ensure compliance \kith federal regulations and the State Plan. All documents established by the Department to evaluate and conclude participants are eligible. need to be obtained and evidenced in the participant's file. The Department should also properly communicate eligibility verification procedures to employees and provide a clear outline as to the tasks. responsibilities_ and supervision and approval tasks for each employee within the eligibility verification process. In case any document established for verification of eligibility is temporarily waived due to specific reasons (natural disasters, pandemic, etc.) the Department should formally communicate the provisions of the temporary waiver. obtain approval of the federal awarding agency, and formal communication should be included in the participant's file. Questioned Costs: Could not be determined. Management's Response: Refer to Grantee's Corrective Action Plan_

Criteria: The Department as an eligible State has submitted to the Secretary of the t U.S. Treasury a State Plan that outlines the way the State intends to conduct the TANF program as requested by 42 U.S.C. Part 602 Section (a)( I )(A)(i). The State Plan shall set forth objective criteria for the delivery of benefits and the determination of eligibility and for fair and equitable treatment. including an explanation of how the State will provide opportunities for recipients who have been adversely affected to be heard in a State administrative or appeal process as required by 42 U.S.C. Part 602 Section (a) (I) (B) (iii). The Temporary Assistance for Needy Families Program State Plan of Operation for fiscal years 2021 through 2023 of the Government of Puerto Rico (the State Plan). Chapter IV-Application Process. establishes financial and non-financial eligibility requirements for applications and redeterminations; the assistance unit that will be considered for benefits and services; supportive evidence of eligibility requirements; and other eligibility factors and criteria. Condition: We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participant/beneficiary was eligible, as required by the Department procedures and federal law. As a result. we could not conclude participants reviewed were eligible to receive benefits as required by the federal award. Perspective - We selected a sample of fifteen (15) participant tiles as part of compliance testing regarding eligibility. Auditors noted several cases in which the following documentation was not present in participants' files as follows: • (1) Participant file was not provided. • (2) Evidence of residence verification • (2) USA Citizenship or Verification of Alien Status form • (2) No copy of Social Security ID or SAIC verification form of participant • (2) Verification of valid ID The above documentation is required as part of the eligibility controls established in the program's state plan to prove the existence of participants. Effect: fhe Department may be qualifying participants who do not meet the eligibility requirements established by federal regulations. This may ultimately result in sanctions. reduced funding. having to return monies to the federal agency. or cancellation of grants. Cause: The Department is not adhering to the established internal control procedures and not adequately documenting its evaluation and conclusion regarding the eligibility of participants. Recommendation: The Department must adhere to its existing internal control procedures to properly document eligibility verification procedures performed and to ensure compliance with federal regulations and the State Plan. All documents established by the Department to evaluate and conclude participants are eligible, need to be obtained and evidenced in the participant's file. The Department should also properly communicate eligibility verification procedures to employees and provide a clear outline as to the tasks. responsibilities, and supervision and approval tasks for each employee within the eligibility verification process. In case. any document established for verification of eligibility is temporarily waived due to specific reasons (natural disasters. pandemic. etc.) the Department should formally communicate the provisions of the temporary waiver, obtain approval of the federal awarding agency. and formal communication should be included in the participant's file. Questioned Costs: Could not be determined. Management's Response: Refer to Grantee's Corrective Action Plan.

Criteria: Each state shall participate in the Income ligibility and Verification System (IEVS) required by Section 1137 of the Social Security Act as amended. Under the state plan the state is required to coordinate data exchanges with other federally assisted benefit programs. request and use income and benefit information when making eligibility determinations and adhere to standardized forniat•,, and procedures in exchanging information with other programs and agencies. The Departments Local Office Procedure Manual (the -Manual."). establishes the following procedures for the exchange of information of persons receiving Social Security Benefits (BENDEX): (a) The BENDEX list is issued monthly to the Director of each Region. (b) The Regional Director sends it to the corresponding local office. (c) The list is assigned and delivered to the technicians to crosscheck the information of the list with the participants' file. (d) The technicians will make a note on the Daily Contact Form (ADSEF-106G) including the finding, date of crosscheck. and name. In the BENDEX list the technicians must write their initials and the date on which the evaluation was made. Condition: We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participantbeneficiary vvas eligible. as required by the Department procedures and federal law. As a result. we could not conclude participants rev loved were eligible to receive benefits as required by the federal award. Perspective - We selected a sample of fifteen (15) participant files as part of compliance testing regarding eligibility. We noted several cases in which the following documentation was not present in participants" files as follows: • (2) Child Support Cooperation Agreement for non-custodial parents. (Cat. C) • (1) Evidence of' residence. (Cat. A) • (2) Verification of Valid ID. (Cat. A) • (1) Medical Certification From Specialist Form (TANF-34). (Cat. D) • (1) Participant file was not available for our review (Cat. C) The Child Support Cooperation Agreement for non-custodial parents is an eligibility requirement for all Category C participants as evidence of custodial parent's cooperation with the ASUME, administration in identifying the minor's father and establishing an alimony. The Valid Identification is an eligibility control established in the program's state plan to prove the existence of participants. The Medical Certification From Specialist Form (TANF-34) is an eligibility requirement that must be provided by applicants under category D to certify that they are incapable of compliance with work, study. or training requirements due to their mental or physical health. Effect: The Department may be qualifying participants that do not meet the eligibility requirements established by federal regulations. This may ultimately result in sanctions. reduced funding. having to return monies to the federal agency. or cancellation of grants. Cause: The Department is not adhering to the established internal control procedures and not adequately documenting its evaluation and conclusion over the eligibility of participants. Recommendation: The Department must adhere to its existing internal control procedures to properly document eligibility verification procedures performed and to ensure compliance with federal regulations and the State Plan. All documents established by the Department to evaluate and conclude participants are eligible. need to be obtained and evidenced in the participant's tile. The Department should also properly communicate eligibility verification procedures to employees and provide a clear outline as to the tasks. responsibilities. and supervision and approval tasks for each employee within the eligibility verification process. In case any document established for verification of eligibility is temporarily waived due to specific reasons (natural disasters, pandemic, etc.) the Department should formally communicate the provisions of the temporary waiver, obtain approval from the federal awarding agency. and formal communication should be included in the participant's file. Questioned Costs: Could not be determined. Management's Response: Refer to Grantee's Corrective Action Plan.

Criteria: Uniform Administrative Requirements. Cost Principles, and Audit Requirements for Federal Awards. Part 200.512, Report Submission. (a) General. (1) states that the audit must be completed, and the data collection form and reporting package must be submitted wiithin the earlier of 30 calendar days after receipt of the auditors' report(s). or nine months after the end of the audit period. Condition: The Department did not comply with the required due date for the submission of the Single Audit Report Package as a result of-systematic issues which hay e led to delays in the receipt and processing of information required as part of the Single Audit. Effect: The Department will be considered delinquent in the submission of the Single Audit Report Package and if it does not respond to follow-up procedures from federal agencies. may face sanctions such as: • Draw-Down Restrictions • Reimbursable Draw Down • Withholding a Percentage of Federal Funds • Suspension of Federal Funds • Termination of Grant Cause: During March 2020, the government of Puerto Rico declared a general lockdovvn as a result of the COVID-19 Pandemic which had a significant impact in governmental agencies and businesses across Puerto Rico. delaying operations on an island-wide scale. This resulted in significant delays in the completion of the Single audits for the past fiscal periods which in turn has resulted in complications regarding filing within required deadlines. Recommendation: The Department must designate work teams amongst all relevant administrations which serve as liaisons vvith auditors and be responsible for the delivery of information and documentation to ensure compliance with due dates. The Department should maintain a clear line of communication throughout its administrations and follow up accordingly to maintain a continuous flow of information during audit procedures. In addition, the Department should request periodic follovv-up meetings with auditors to address any audit issues encountered which may affect meeting established deadlines. Questioned Costs: None Management's Response: Refer to Grantee's Corrective Action Plan.

Criteria: The Department is required to identity in its annual plan the population eligible for NAP benefits, In testing the propriety of eligibility determinations and disbursements for NAP benefits, the auditor shall apply the eligibility criteria established by the Department and identified in the annual plan (7 CFR section 285.3(b)(2)). 7 CFR Part 285 Section 3 - Plan of Operation. states (b) the plan of operation shall include the following, information: ( 2) A description of the needy persons residing in the Commonwealth of Puerto Rico and an assessment of the food and nutrition needs of these persons, The description and assessment shall demonstrate that the Nutrition Assistance Program is directed toward the neediest persons in the Commonwealth of Puerto Rico. We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participantlbeneficiary was eligible. as required by the Department procedures and federal law. As a result. we could not conclude participants reviewed were eligible to receive benefits as required by the federal award. Perspective We selected a sample of forty (40) participant files as part of compliance testing regarding eligibility. Auditors noted several cases in which the following documentation was not present in participants' tiles as follows: • (2) Verification of valid ID • (2) Evidence of residence • (3) Release of information form • (2) USA Citizenship or Verification of Alien Status form • (2) No copy of Social Security ID or SAID.' verification form of participants • (2) Resource Verification Form ($5k-$15k) • (2) Determination form • (2) Notification Advice form The above documentation is required as part of the eligibility controls established in the program's state plan to prove the existence of participants. Effect: The Department may be qualifying participants who do not meet the eligibility requirements established by federal regulations. T his may ultimately result in sanctions, reduced funding. having to return monies to the federal agency. or cancellation of grants. Cause: The Department is not adhering to the established internal control procedures and not adequately documenting its evaluation and conclusion over the eligibility of participants. Recommendation: The Department must adhere to its existing internal control procedures to properly document eligibility verification procedures performed and to ensure compliance \kith federal regulations and the State Plan. All documents established by the Department to evaluate and conclude participants are eligible. need to be obtained and evidenced in the participant's file. The Department should also properly communicate eligibility verification procedures to employees and provide a clear outline as to the tasks. responsibilities_ and supervision and approval tasks for each employee within the eligibility verification process. In case any document established for verification of eligibility is temporarily waived due to specific reasons (natural disasters, pandemic, etc.) the Department should formally communicate the provisions of the temporary waiver. obtain approval of the federal awarding agency, and formal communication should be included in the participant's file. Questioned Costs: Could not be determined. Management's Response: Refer to Grantee's Corrective Action Plan_

Criteria: The Department as an eligible State has submitted to the Secretary of the t U.S. Treasury a State Plan that outlines the way the State intends to conduct the TANF program as requested by 42 U.S.C. Part 602 Section (a)( I )(A)(i). The State Plan shall set forth objective criteria for the delivery of benefits and the determination of eligibility and for fair and equitable treatment. including an explanation of how the State will provide opportunities for recipients who have been adversely affected to be heard in a State administrative or appeal process as required by 42 U.S.C. Part 602 Section (a) (I) (B) (iii). The Temporary Assistance for Needy Families Program State Plan of Operation for fiscal years 2021 through 2023 of the Government of Puerto Rico (the State Plan). Chapter IV-Application Process. establishes financial and non-financial eligibility requirements for applications and redeterminations; the assistance unit that will be considered for benefits and services; supportive evidence of eligibility requirements; and other eligibility factors and criteria. Condition: We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participant/beneficiary was eligible, as required by the Department procedures and federal law. As a result. we could not conclude participants reviewed were eligible to receive benefits as required by the federal award. Perspective - We selected a sample of fifteen (15) participant tiles as part of compliance testing regarding eligibility. Auditors noted several cases in which the following documentation was not present in participants' files as follows: • (1) Participant file was not provided. • (2) Evidence of residence verification • (2) USA Citizenship or Verification of Alien Status form • (2) No copy of Social Security ID or SAIC verification form of participant • (2) Verification of valid ID The above documentation is required as part of the eligibility controls established in the program's state plan to prove the existence of participants. Effect: fhe Department may be qualifying participants who do not meet the eligibility requirements established by federal regulations. This may ultimately result in sanctions. reduced funding. having to return monies to the federal agency. or cancellation of grants. Cause: The Department is not adhering to the established internal control procedures and not adequately documenting its evaluation and conclusion regarding the eligibility of participants. Recommendation: The Department must adhere to its existing internal control procedures to properly document eligibility verification procedures performed and to ensure compliance with federal regulations and the State Plan. All documents established by the Department to evaluate and conclude participants are eligible, need to be obtained and evidenced in the participant's file. The Department should also properly communicate eligibility verification procedures to employees and provide a clear outline as to the tasks. responsibilities, and supervision and approval tasks for each employee within the eligibility verification process. In case. any document established for verification of eligibility is temporarily waived due to specific reasons (natural disasters. pandemic. etc.) the Department should formally communicate the provisions of the temporary waiver, obtain approval of the federal awarding agency. and formal communication should be included in the participant's file. Questioned Costs: Could not be determined. Management's Response: Refer to Grantee's Corrective Action Plan.

Criteria: Each state shall participate in the Income ligibility and Verification System (IEVS) required by Section 1137 of the Social Security Act as amended. Under the state plan the state is required to coordinate data exchanges with other federally assisted benefit programs. request and use income and benefit information when making eligibility determinations and adhere to standardized forniat•,, and procedures in exchanging information with other programs and agencies. The Departments Local Office Procedure Manual (the -Manual."). establishes the following procedures for the exchange of information of persons receiving Social Security Benefits (BENDEX): (a) The BENDEX list is issued monthly to the Director of each Region. (b) The Regional Director sends it to the corresponding local office. (c) The list is assigned and delivered to the technicians to crosscheck the information of the list with the participants' file. (d) The technicians will make a note on the Daily Contact Form (ADSEF-106G) including the finding, date of crosscheck. and name. In the BENDEX list the technicians must write their initials and the date on which the evaluation was made. Condition: We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participantbeneficiary vvas eligible. as required by the Department procedures and federal law. As a result. we could not conclude participants rev loved were eligible to receive benefits as required by the federal award. Perspective - We selected a sample of fifteen (15) participant files as part of compliance testing regarding eligibility. We noted several cases in which the following documentation was not present in participants" files as follows: • (2) Child Support Cooperation Agreement for non-custodial parents. (Cat. C) • (1) Evidence of' residence. (Cat. A) • (2) Verification of Valid ID. (Cat. A) • (1) Medical Certification From Specialist Form (TANF-34). (Cat. D) • (1) Participant file was not available for our review (Cat. C) The Child Support Cooperation Agreement for non-custodial parents is an eligibility requirement for all Category C participants as evidence of custodial parent's cooperation with the ASUME, administration in identifying the minor's father and establishing an alimony. The Valid Identification is an eligibility control established in the program's state plan to prove the existence of participants. The Medical Certification From Specialist Form (TANF-34) is an eligibility requirement that must be provided by applicants under category D to certify that they are incapable of compliance with work, study. or training requirements due to their mental or physical health. Effect: The Department may be qualifying participants that do not meet the eligibility requirements established by federal regulations. This may ultimately result in sanctions. reduced funding. having to return monies to the federal agency. or cancellation of grants. Cause: The Department is not adhering to the established internal control procedures and not adequately documenting its evaluation and conclusion over the eligibility of participants. Recommendation: The Department must adhere to its existing internal control procedures to properly document eligibility verification procedures performed and to ensure compliance with federal regulations and the State Plan. All documents established by the Department to evaluate and conclude participants are eligible. need to be obtained and evidenced in the participant's tile. The Department should also properly communicate eligibility verification procedures to employees and provide a clear outline as to the tasks. responsibilities. and supervision and approval tasks for each employee within the eligibility verification process. In case any document established for verification of eligibility is temporarily waived due to specific reasons (natural disasters, pandemic, etc.) the Department should formally communicate the provisions of the temporary waiver, obtain approval from the federal awarding agency. and formal communication should be included in the participant's file. Questioned Costs: Could not be determined. Management's Response: Refer to Grantee's Corrective Action Plan.

Criteria: Uniform Administrative Requirements. Cost Principles, and Audit Requirements for Federal Awards. Part 200.512, Report Submission. (a) General. (1) states that the audit must be completed, and the data collection form and reporting package must be submitted wiithin the earlier of 30 calendar days after receipt of the auditors' report(s). or nine months after the end of the audit period. Condition: The Department did not comply with the required due date for the submission of the Single Audit Report Package as a result of-systematic issues which hay e led to delays in the receipt and processing of information required as part of the Single Audit. Effect: The Department will be considered delinquent in the submission of the Single Audit Report Package and if it does not respond to follow-up procedures from federal agencies. may face sanctions such as: • Draw-Down Restrictions • Reimbursable Draw Down • Withholding a Percentage of Federal Funds • Suspension of Federal Funds • Termination of Grant Cause: During March 2020, the government of Puerto Rico declared a general lockdovvn as a result of the COVID-19 Pandemic which had a significant impact in governmental agencies and businesses across Puerto Rico. delaying operations on an island-wide scale. This resulted in significant delays in the completion of the Single audits for the past fiscal periods which in turn has resulted in complications regarding filing within required deadlines. Recommendation: The Department must designate work teams amongst all relevant administrations which serve as liaisons vvith auditors and be responsible for the delivery of information and documentation to ensure compliance with due dates. The Department should maintain a clear line of communication throughout its administrations and follow up accordingly to maintain a continuous flow of information during audit procedures. In addition, the Department should request periodic follovv-up meetings with auditors to address any audit issues encountered which may affect meeting established deadlines. Questioned Costs: None Management's Response: Refer to Grantee's Corrective Action Plan.