2022-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster COVID-19 ? Community Development Block Grant - CV Assistance Listing Number: 14.218 Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control over Compliance, Material Non-Compliance Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Condition: Subaward information was not reported to FSRS during FY 2022. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Context: Zero of five subawards selected for testing were reported to FSRS. Total subawards tested were $1,434,300, and $0 was reported as required by FFATA requirements. "See Schedule of Findings and Questioned Costs for Chart/Table" Cause: Due to staffing shortages, the City did not have the resources to input all subaward information into the FSRS system. Effect: Subawards were not reported in FRSR in accordance with FFATA requirements. Questioned costs: None Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Views of Responsible Officials: The City agrees with this finding. See separate Correction Action Plan related to this finding.
2022-005 Federal Agency: U.S. Department of Social Services Federal Program Name: Temporary Assistance for Needy Families ALN: 93.558 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: A financially needed family that consists of a minor child living with a parent/caretaker relative or pregnant woman may receive TANF assistance. The child must be less than 18 years old or less than 19 years old if a full-time student in a secondary school. Recipients must be United States citizens or qualified aliens. Assistance is provided for up to 60 months and can be extended if specific requirements are met. Assistance may not be provided to/for: ? An unmarried individual under 18 years old with a child (minor parent) who has not completed high school/equivalent unless the individual is working toward attaining a high school diploma or participating in an alternative education/training program. ? An unmarried individual under 18 with a child if the minor parent and child are not living with a parent, legal guardian, or an adult relative. ? Minor child that has or is expected to be absent from the home for 45 consecutive days or at the option of a State between 30-180 days. ? An individual fleeing to avoid prosecution or custody for a felony, confinement after a conviction of a felony, or in violation of probation/parole terms. ? An individual convicted of fraudulent representation for assistance within the past ten years. As a condition of receiving assistance, families must assign the rights of any support received from any other person to the State. Condition: A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 case files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Questioned Costs: None Cause: The case notes in the system of record referenced various verification methods and documentation that was obtained. However, the documentation could not be located and provided to the auditors. Per DSS management, limited staffing working the volume of cases is an attributing factor for the observations. The verifications were not conducted, and/or the documentation was not placed in the case files. A quality control process is not in place to ensure that eligibility verifications are conducted, and documentation is obtained and retained in the case files. Effect: Applicants that do not meet TANF requirements may be inappropriately screened eligible and receive benefits. Also, incomplete case files hinder RDSS?s ability to support eligibility screening decisions. Recommendation: We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-005 Federal Agency: U.S. Department of Social Services Federal Program Name: Temporary Assistance for Needy Families ALN: 93.558 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: A financially needed family that consists of a minor child living with a parent/caretaker relative or pregnant woman may receive TANF assistance. The child must be less than 18 years old or less than 19 years old if a full-time student in a secondary school. Recipients must be United States citizens or qualified aliens. Assistance is provided for up to 60 months and can be extended if specific requirements are met. Assistance may not be provided to/for: ? An unmarried individual under 18 years old with a child (minor parent) who has not completed high school/equivalent unless the individual is working toward attaining a high school diploma or participating in an alternative education/training program. ? An unmarried individual under 18 with a child if the minor parent and child are not living with a parent, legal guardian, or an adult relative. ? Minor child that has or is expected to be absent from the home for 45 consecutive days or at the option of a State between 30-180 days. ? An individual fleeing to avoid prosecution or custody for a felony, confinement after a conviction of a felony, or in violation of probation/parole terms. ? An individual convicted of fraudulent representation for assistance within the past ten years. As a condition of receiving assistance, families must assign the rights of any support received from any other person to the State. Condition: A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 case files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Questioned Costs: None Cause: The case notes in the system of record referenced various verification methods and documentation that was obtained. However, the documentation could not be located and provided to the auditors. Per DSS management, limited staffing working the volume of cases is an attributing factor for the observations. The verifications were not conducted, and/or the documentation was not placed in the case files. A quality control process is not in place to ensure that eligibility verifications are conducted, and documentation is obtained and retained in the case files. Effect: Applicants that do not meet TANF requirements may be inappropriately screened eligible and receive benefits. Also, incomplete case files hinder RDSS?s ability to support eligibility screening decisions. Recommendation: We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-005 Federal Agency: U.S. Department of Social Services Federal Program Name: Temporary Assistance for Needy Families ALN: 93.558 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: A financially needed family that consists of a minor child living with a parent/caretaker relative or pregnant woman may receive TANF assistance. The child must be less than 18 years old or less than 19 years old if a full-time student in a secondary school. Recipients must be United States citizens or qualified aliens. Assistance is provided for up to 60 months and can be extended if specific requirements are met. Assistance may not be provided to/for: ? An unmarried individual under 18 years old with a child (minor parent) who has not completed high school/equivalent unless the individual is working toward attaining a high school diploma or participating in an alternative education/training program. ? An unmarried individual under 18 with a child if the minor parent and child are not living with a parent, legal guardian, or an adult relative. ? Minor child that has or is expected to be absent from the home for 45 consecutive days or at the option of a State between 30-180 days. ? An individual fleeing to avoid prosecution or custody for a felony, confinement after a conviction of a felony, or in violation of probation/parole terms. ? An individual convicted of fraudulent representation for assistance within the past ten years. As a condition of receiving assistance, families must assign the rights of any support received from any other person to the State. Condition: A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 case files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Questioned Costs: None Cause: The case notes in the system of record referenced various verification methods and documentation that was obtained. However, the documentation could not be located and provided to the auditors. Per DSS management, limited staffing working the volume of cases is an attributing factor for the observations. The verifications were not conducted, and/or the documentation was not placed in the case files. A quality control process is not in place to ensure that eligibility verifications are conducted, and documentation is obtained and retained in the case files. Effect: Applicants that do not meet TANF requirements may be inappropriately screened eligible and receive benefits. Also, incomplete case files hinder RDSS?s ability to support eligibility screening decisions. Recommendation: We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-004 Federal Agency: U.S. Department of Social Services Federal Program Name: Title ? IV-E Adoption Assistance ALN: 93.659 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: Title IV-E of the Social Security Act (42 U.S.C ?670) authorizes the Adoption Assistance program. Subsidy payments are made to the adoptive parent(s) based on a child?s needs (i.e., development, cognitive, or emotional behavior) and the adoptive parent(s)? circumstances. Payments are issued in accordance with a written and binding adoption assistance agreement (AAA) when the below eligibility requirements are met. ? Child meets the categorical eligibility as an ?Applicable Child? or ?Non-Applicable Child.? o Applicable child - AAA was signed in federal fiscal year (FY) 2010 or later that met the age requirement; or who was in foster care for at least 60 consecutive months; or who has a sibling in the same adoptive placement that meets one of the above requirements. Also, the child must meet one of the below requirements. ? was in foster care when the adoption proceeds were initiated; or ? meets disability or medical requirements for the Supplemental Security Income (SSI) program; or ? was residing with a minor parent in foster care: or ? was eligible for adoption assistance in a previous adoption in which the adoptive parent died or parental rights were terminated. o Non-applicable ? AAA was signed prior to federal FY10 or a later year if the applicable requirements were not met and the child meets one of the below requirements: ? eligible for the Aid to Families with Dependent Children (AFDC) program; or ? eligible for SSI; or ? resides with a minor parent in foster care that is receiving Title IV-E foster care maintenance payments for themselves and the child. ? The child cannot or should not return home to his/her parents. ? The child has a special need (i.e., minority or medical condition), and it is reasonable to conclude that the child cannot be placed with adoptive parents without providing a subsidy. ? The agency made reasonable efforts to place the child without a subsidy or waive the requirement if not in the best interest of the child. ? The AAA was signed prior to the final decree of adoption. ? Criminal records checks were conducted for the prospective adoptive parent(s) and child abuse and neglect registry checks were conducted for the prospective adoptive parents and adult household members. Also, the subsidy payment cannot exceed the foster care maintenance payment the child would have received in foster care. Condition: A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibility requirements, had special needs that prevented them from being placed without a subsidy, and could not return home. ? 40 out of 40 children - RDSS made reasonable efforts to place the children without the subsidy or waived the requirement as it was not in the best interest of the child. ? 40 out of 40 children ? The adoption assistance agreements were signed prior to the final adoption decree, the authorized amounts were in line with the State?s rates, and payments were issued in accordance with the agreements. ? 9 out of 40 children ? Sufficient evidence of the completion of the required criminal background and child abuse and neglect registry checks for the adoptive parents and adult household members was not in the adoption case files. The home studies and report of investigations narrative indicated the required checks were completed for the adoptive parents and household members but did not identify when they occurred. Also, in some cases, it was not noted if the adoptive parents met the eligibility requirements for the criminal record checks. As such, the auditors were unable to confirm when the checks occurred, and supporting documentation was not provided prior to the completion of fieldwork. In addition, during the initial file review, documents such as court orders, negotiation documents, and annual affidavits were missing from some of the files. The Adoption Unit was ultimately able to retrieve and provide the missing items. However, an opportunity exists to improve the adoption case file documentation. Questioned Costs: None Cause: The home studies and background checks were conducted by child-placing agencies, DSS Resource Unit, or third parties. Standard documentation requirements regarding background checks were not in place. As such, there was an inconsistency in the information captured in the home studies and provided to support the completion of the criminal background and child abuse and neglect registry checks. The capture information ranged for the home study narratives to non-conviction letters. A quality control process was not in place to ensure that the required documentation was maintained in the adoption case files. Effect: The lack of a quality control process resulted in incomplete adoption case files, which may result in noncompliance with the adoption assistance requirements or prevent the Unit from demonstrating compliance. Also, the inconsistencies in the background check documentation reduce the Unit?s assurance and ability to demonstrate that the required checks were conducted. As such, this could result in kids being potentially placed in unsafe environments and the State or Federal government clawing back Title IV-E funds for non-compliance. Recommendation: We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster COVID-19 ? Community Development Block Grant - CV Assistance Listing Number: 14.218 Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control over Compliance, Material Non-Compliance Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Condition: Subaward information was not reported to FSRS during FY 2022. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Context: Zero of five subawards selected for testing were reported to FSRS. Total subawards tested were $1,434,300, and $0 was reported as required by FFATA requirements. "See Schedule of Findings and Questioned Costs for Chart/Table" Cause: Due to staffing shortages, the City did not have the resources to input all subaward information into the FSRS system. Effect: Subawards were not reported in FRSR in accordance with FFATA requirements. Questioned costs: None Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Views of Responsible Officials: The City agrees with this finding. See separate Correction Action Plan related to this finding.
2022-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster COVID-19 ? Community Development Block Grant - CV Assistance Listing Number: 14.218 Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control over Compliance, Material Non-Compliance Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Condition: Subaward information was not reported to FSRS during FY 2022. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Context: Zero of five subawards selected for testing were reported to FSRS. Total subawards tested were $1,434,300, and $0 was reported as required by FFATA requirements. "See Schedule of Findings and Questioned Costs for Chart/Table" Cause: Due to staffing shortages, the City did not have the resources to input all subaward information into the FSRS system. Effect: Subawards were not reported in FRSR in accordance with FFATA requirements. Questioned costs: None Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Views of Responsible Officials: The City agrees with this finding. See separate Correction Action Plan related to this finding.
2022-005 Federal Agency: U.S. Department of Social Services Federal Program Name: Temporary Assistance for Needy Families ALN: 93.558 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: A financially needed family that consists of a minor child living with a parent/caretaker relative or pregnant woman may receive TANF assistance. The child must be less than 18 years old or less than 19 years old if a full-time student in a secondary school. Recipients must be United States citizens or qualified aliens. Assistance is provided for up to 60 months and can be extended if specific requirements are met. Assistance may not be provided to/for: ? An unmarried individual under 18 years old with a child (minor parent) who has not completed high school/equivalent unless the individual is working toward attaining a high school diploma or participating in an alternative education/training program. ? An unmarried individual under 18 with a child if the minor parent and child are not living with a parent, legal guardian, or an adult relative. ? Minor child that has or is expected to be absent from the home for 45 consecutive days or at the option of a State between 30-180 days. ? An individual fleeing to avoid prosecution or custody for a felony, confinement after a conviction of a felony, or in violation of probation/parole terms. ? An individual convicted of fraudulent representation for assistance within the past ten years. As a condition of receiving assistance, families must assign the rights of any support received from any other person to the State. Condition: A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 case files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Questioned Costs: None Cause: The case notes in the system of record referenced various verification methods and documentation that was obtained. However, the documentation could not be located and provided to the auditors. Per DSS management, limited staffing working the volume of cases is an attributing factor for the observations. The verifications were not conducted, and/or the documentation was not placed in the case files. A quality control process is not in place to ensure that eligibility verifications are conducted, and documentation is obtained and retained in the case files. Effect: Applicants that do not meet TANF requirements may be inappropriately screened eligible and receive benefits. Also, incomplete case files hinder RDSS?s ability to support eligibility screening decisions. Recommendation: We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-005 Federal Agency: U.S. Department of Social Services Federal Program Name: Temporary Assistance for Needy Families ALN: 93.558 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: A financially needed family that consists of a minor child living with a parent/caretaker relative or pregnant woman may receive TANF assistance. The child must be less than 18 years old or less than 19 years old if a full-time student in a secondary school. Recipients must be United States citizens or qualified aliens. Assistance is provided for up to 60 months and can be extended if specific requirements are met. Assistance may not be provided to/for: ? An unmarried individual under 18 years old with a child (minor parent) who has not completed high school/equivalent unless the individual is working toward attaining a high school diploma or participating in an alternative education/training program. ? An unmarried individual under 18 with a child if the minor parent and child are not living with a parent, legal guardian, or an adult relative. ? Minor child that has or is expected to be absent from the home for 45 consecutive days or at the option of a State between 30-180 days. ? An individual fleeing to avoid prosecution or custody for a felony, confinement after a conviction of a felony, or in violation of probation/parole terms. ? An individual convicted of fraudulent representation for assistance within the past ten years. As a condition of receiving assistance, families must assign the rights of any support received from any other person to the State. Condition: A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 case files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Questioned Costs: None Cause: The case notes in the system of record referenced various verification methods and documentation that was obtained. However, the documentation could not be located and provided to the auditors. Per DSS management, limited staffing working the volume of cases is an attributing factor for the observations. The verifications were not conducted, and/or the documentation was not placed in the case files. A quality control process is not in place to ensure that eligibility verifications are conducted, and documentation is obtained and retained in the case files. Effect: Applicants that do not meet TANF requirements may be inappropriately screened eligible and receive benefits. Also, incomplete case files hinder RDSS?s ability to support eligibility screening decisions. Recommendation: We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-005 Federal Agency: U.S. Department of Social Services Federal Program Name: Temporary Assistance for Needy Families ALN: 93.558 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: A financially needed family that consists of a minor child living with a parent/caretaker relative or pregnant woman may receive TANF assistance. The child must be less than 18 years old or less than 19 years old if a full-time student in a secondary school. Recipients must be United States citizens or qualified aliens. Assistance is provided for up to 60 months and can be extended if specific requirements are met. Assistance may not be provided to/for: ? An unmarried individual under 18 years old with a child (minor parent) who has not completed high school/equivalent unless the individual is working toward attaining a high school diploma or participating in an alternative education/training program. ? An unmarried individual under 18 with a child if the minor parent and child are not living with a parent, legal guardian, or an adult relative. ? Minor child that has or is expected to be absent from the home for 45 consecutive days or at the option of a State between 30-180 days. ? An individual fleeing to avoid prosecution or custody for a felony, confinement after a conviction of a felony, or in violation of probation/parole terms. ? An individual convicted of fraudulent representation for assistance within the past ten years. As a condition of receiving assistance, families must assign the rights of any support received from any other person to the State. Condition: A sample of 40 FY2022 TANF cases was tested for compliance with the above criteria and the observations were noted below. ? 24 out of 40 case files tested did not contain adequate documentation to verify eligibility requirements and approval of benefits. Approximately, 55% of the reviewed files lacked evidence that the workers verified the relationship between the minor children and the applicant and that the children were living in the home. ? 1 out of 40 case files tested, the assistance unit captured a child that was not living in the household, which inappropriately increased the monthly benefit amount. ? 1 out of the 40 cases tested did not contain evidence that the eligibility worker inquired about the applicant?s indication on the application that they were not in compliance with probation/sentencing terms prior to approving the application. Questioned Costs: None Cause: The case notes in the system of record referenced various verification methods and documentation that was obtained. However, the documentation could not be located and provided to the auditors. Per DSS management, limited staffing working the volume of cases is an attributing factor for the observations. The verifications were not conducted, and/or the documentation was not placed in the case files. A quality control process is not in place to ensure that eligibility verifications are conducted, and documentation is obtained and retained in the case files. Effect: Applicants that do not meet TANF requirements may be inappropriately screened eligible and receive benefits. Also, incomplete case files hinder RDSS?s ability to support eligibility screening decisions. Recommendation: We recommend that the Economic Support and Independence Deputy Director develop and implement a quality control process to ensure the required eligibility verifications are conducted and properly documented in the case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-004 Federal Agency: U.S. Department of Social Services Federal Program Name: Title ? IV-E Adoption Assistance ALN: 93.659 Award Period: July 1, 2021 ? June 30, 2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Prior Year Finding: No Criteria: Title IV-E of the Social Security Act (42 U.S.C ?670) authorizes the Adoption Assistance program. Subsidy payments are made to the adoptive parent(s) based on a child?s needs (i.e., development, cognitive, or emotional behavior) and the adoptive parent(s)? circumstances. Payments are issued in accordance with a written and binding adoption assistance agreement (AAA) when the below eligibility requirements are met. ? Child meets the categorical eligibility as an ?Applicable Child? or ?Non-Applicable Child.? o Applicable child - AAA was signed in federal fiscal year (FY) 2010 or later that met the age requirement; or who was in foster care for at least 60 consecutive months; or who has a sibling in the same adoptive placement that meets one of the above requirements. Also, the child must meet one of the below requirements. ? was in foster care when the adoption proceeds were initiated; or ? meets disability or medical requirements for the Supplemental Security Income (SSI) program; or ? was residing with a minor parent in foster care: or ? was eligible for adoption assistance in a previous adoption in which the adoptive parent died or parental rights were terminated. o Non-applicable ? AAA was signed prior to federal FY10 or a later year if the applicable requirements were not met and the child meets one of the below requirements: ? eligible for the Aid to Families with Dependent Children (AFDC) program; or ? eligible for SSI; or ? resides with a minor parent in foster care that is receiving Title IV-E foster care maintenance payments for themselves and the child. ? The child cannot or should not return home to his/her parents. ? The child has a special need (i.e., minority or medical condition), and it is reasonable to conclude that the child cannot be placed with adoptive parents without providing a subsidy. ? The agency made reasonable efforts to place the child without a subsidy or waive the requirement if not in the best interest of the child. ? The AAA was signed prior to the final decree of adoption. ? Criminal records checks were conducted for the prospective adoptive parent(s) and child abuse and neglect registry checks were conducted for the prospective adoptive parents and adult household members. Also, the subsidy payment cannot exceed the foster care maintenance payment the child would have received in foster care. Condition: A sample of 40 children that received Title IV-E adoption subsidies during FY2022 was tested for compliance with the above criteria and the observations were noted below. ? 40 out of 40 children - Met the eligibility requirements, had special needs that prevented them from being placed without a subsidy, and could not return home. ? 40 out of 40 children - RDSS made reasonable efforts to place the children without the subsidy or waived the requirement as it was not in the best interest of the child. ? 40 out of 40 children ? The adoption assistance agreements were signed prior to the final adoption decree, the authorized amounts were in line with the State?s rates, and payments were issued in accordance with the agreements. ? 9 out of 40 children ? Sufficient evidence of the completion of the required criminal background and child abuse and neglect registry checks for the adoptive parents and adult household members was not in the adoption case files. The home studies and report of investigations narrative indicated the required checks were completed for the adoptive parents and household members but did not identify when they occurred. Also, in some cases, it was not noted if the adoptive parents met the eligibility requirements for the criminal record checks. As such, the auditors were unable to confirm when the checks occurred, and supporting documentation was not provided prior to the completion of fieldwork. In addition, during the initial file review, documents such as court orders, negotiation documents, and annual affidavits were missing from some of the files. The Adoption Unit was ultimately able to retrieve and provide the missing items. However, an opportunity exists to improve the adoption case file documentation. Questioned Costs: None Cause: The home studies and background checks were conducted by child-placing agencies, DSS Resource Unit, or third parties. Standard documentation requirements regarding background checks were not in place. As such, there was an inconsistency in the information captured in the home studies and provided to support the completion of the criminal background and child abuse and neglect registry checks. The capture information ranged for the home study narratives to non-conviction letters. A quality control process was not in place to ensure that the required documentation was maintained in the adoption case files. Effect: The lack of a quality control process resulted in incomplete adoption case files, which may result in noncompliance with the adoption assistance requirements or prevent the Unit from demonstrating compliance. Also, the inconsistencies in the background check documentation reduce the Unit?s assurance and ability to demonstrate that the required checks were conducted. As such, this could result in kids being potentially placed in unsafe environments and the State or Federal government clawing back Title IV-E funds for non-compliance. Recommendation: We recommend that the Children, Families, and Adults (CFA) Deputy Director develop and implement a quality control process to ensure that the required documentation is maintained in the adoption case files. We recommend that the CFA Deputy Director develop and implement standard documentation requirements for documenting the completion of the background checks in the adoption case files. Views of Responsible Officials and Planned Corrective Action: The City agrees with this finding. See separate Corrective Action Plan related to this finding.
2022-006 Federal Agency: U.S. Department of Housing and Urban Development Federal Program: CDBG Entitlement Grant Cluster COVID-19 ? Community Development Block Grant - CV Assistance Listing Number: 14.218 Compliance Requirement: Reporting ? Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control over Compliance, Material Non-Compliance Criteria or specific requirement: Per the Federal Funding Accountability and Transparency Act (FFATA), prime (direct) recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Reports must be filed in FSRS by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If the initial award is below $30,000 but subsequent grant modifications result in a total award equal to or over $30,000, the award will be subject to the reporting requirements as of the date the award exceeds $30,000. If the initial award equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting requirements. The following key data elements must be reported: Subawardee Name and Data Universal Numbering System (DUNS) number; Amount of Subaward (inclusive of modifications); Subaward Obligation/Action Date; Date of Report Submission; Subaward Number; Project Description; and Names and Compensation of Highly Compensated Officers. (Names and Compensation of Highly Compensated Officers must only be reported when the entity in the preceding fiscal year received 80 percent or more of its annual gross revenues in Federal awards; and $30,000,000 or more in annual gross revenues from Federal awards; and the public does not have access to this information about the compensation of the senior executives of the entity through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. ?? 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986.) Condition: Subaward information was not reported to FSRS during FY 2022. Section III ? Findings and Questioned Costs ? Major Federal Programs (Continued) Context: Zero of five subawards selected for testing were reported to FSRS. Total subawards tested were $1,434,300, and $0 was reported as required by FFATA requirements. "See Schedule of Findings and Questioned Costs for Chart/Table" Cause: Due to staffing shortages, the City did not have the resources to input all subaward information into the FSRS system. Effect: Subawards were not reported in FRSR in accordance with FFATA requirements. Questioned costs: None Recommendation: We recommend the City develop internal controls and procedures to ensure that FFATA reporting requirements are met. We further recommend the City develop controls and procedures to ensure that all required subawards are reported accurately and timely to FSRS no later than the end of the month following the month of issuance. Views of Responsible Officials: The City agrees with this finding. See separate Correction Action Plan related to this finding.