Condition We selected a non-statistical sample of 60 case files which approximate $43,500 in monthly benefit payments, out of a population of 381 case files which approximated $3.33 million in total annual benefit payments, for testing and noted exceptions in three case files as follows: • Two files where the state, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing or not completed prior to becoming licensed and receiving benefit payments. • One case file where the “difficulty of care” determination was missing and therefore did not support the assistance amount paid. A similar finding was reported in the prior year as Finding No. 2024-008. Criteria Pursuant to 42 USC 675(4)(A), the foster care maintenance payments should cover the cost of (and the cost of providing) food, clothing, shelter, daily supervision, and a child’s personal incidentals. Pursuant to 42 USC 671(a)(20)(A), any prospective foster parent must satisfactorily have met a criminal records check, including a fingerprint-based check of national crime information databases, before the foster parent may be finally approved for placement of a child. Effect Failure to follow the established policies and procedures in place over the application process and determination of assistance amount represent instances of noncompliance with the requirements above, resulting in questioned costs. Cause and View of Responsible Officials Although the Department has established policies and procedures in place over the application process and determination of assistance amount, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including those specified under the Criteria section above. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition We selected a non-statistical sample of three subrecipients and noted that the Department did not perform site-visits for two subrecipients as required by the Department’s policy and procedures. Criteria Pursuant to 2 CFR 200.332(d), pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Effect Failure to monitor subrecipients increases the risk that noncompliance at the subrecipient level goes undetected. Cause and View of Responsible Officials Although the Department has established policies and procedures in place over the application process and determination of assistance amount, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including those specified under the Criteria section above. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition We selected a non-statistical sample of 60 case files which approximates $29,160 in monthly benefit payments, out of a population of approximately 1,400 case files which approximate $22.2 million in total annual benefit payments, for testing and noted exceptions in 13 case files as follows: • Ten case files where the modified or initial adoption agreement was missing and therefore did not have any support for the amount of monthly assistance paid. • One case file where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing. • Five case files where the “difficulty of care” determination was missing and therefore did not have any support for the assistance amount paid. • Two case files where the documentation regarding the continuation of the monthly subsidy payments after the child’s 18th birthday was missing. A similar finding was reported in the prior year as Finding No. 2024-006. Criteria Pursuant to 42 USC 673(a)(3), the amount of the adoption assistance payments to be made shall be determined through agreement between the adoptive parents and the State or local agency administering the program, which shall take into consideration the circumstances of the adopting parents and the needs of the child being adopted, and may be readjusted periodically, with the concurrence of the adopting parents (which may be specified in the adoption assistance agreement), depending upon changes in such circumstances. Pursuant to 42 USC 671(a)(20)(A), the State must have procedures for criminal records checks, including a fingerprint-based check of national crime information databases (as defined in 28 USC 534(f)(3)(A)), for any prospective adoptive parent before the adoptive parent may be finally approved for placement of a child. Pursuant to 42 USC 673(c)(1)(B), a difficulty of care determination is required to be completed in order to verify that the child qualifies as having special needs. Pursuant to 42 USC 673(a)(4)(A), assistance payments must stop for a child who has attained 18 years of age or greater or 21 years of age if the State determines that the child has a mental or physical handicap. Effect Failure to follow the established policies and procedures in place over the application process and determination of assistance amount represents an instance of noncompliance with the requirements of 2 CFR Part 200, resulting in questioned costs. Cause and View of Responsible Officials Although the Department has established policies and procedures in place regarding the application process and determination of assistance amount, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including those specified under Criteria above. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition We selected a non-statistical sample of 60 case files which approximated $45,440 in monthly benefit payments, out of a population of 361 case files which approximated $4.9 million in total annual benefit payments, for testing and noted exceptions in 13 case files as follows: • Eleven case files where the initial or modified guardianship/permanency assistance agreement was missing and therefore did not have any support for the amount of monthly assistance paid. • Two case file where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing in the case files. A similar finding was reported in the prior year as Finding No. 2024-007. Criteria Pursuant to 42 USC 673(d)(1), an executed kinship guardianship assistance agreement with the prospective relative guardian must include the amount of and any adjustments based on the needs of the child. The "Guardianship/Permanency Assistance Agreement” (“Agreement”) is the agreement executed with the relative guardian. The Agreement outlines the terms and conditions for the participants and the Department and includes the total amount of assistance payments. In the event of an increase or decrease to the amount of the assistance payments, the caseworkers are required to execute a revised Agreement. Pursuant to 42 USC 671(a)(20)(c), any relative guardian must satisfactorily have met a criminal records check, including a fingerprint-based check of national crime information databases (as defined in 28 USC 534(e)(3)(A)), and for checks described in 42 USC 671(a)(20)(B) on any relative guardian and any other adult living in the home of any relative guardian, before the relative guardian may receive kinship guardianship assistance payments on behalf of the child. Effect Failure to follow the established policies and procedures in place over the application process and determination of assistance amount, represents an instance of noncompliance with the requirements specified above, resulting in questioned costs. Cause and View of Responsible Officials Although the Department has established policies and procedures in place over the application process and determination of assistance amount, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements including those specified under the Criteria section above. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition We selected a non-statistical sample of 60 participant files, representing approximately $43,600 of monthly benefit payments, out of a population of approximately 2,500 cases, representing approximately $41.5 million of benefit payments, for testing and noted exceptions in four case files as follows: • Four case files where the interview process was not conducted within the forty-five (45) day timeframe required by the State Plan. A similar finding was reported in the prior year as Finding No. 2024-010. Criteria The State of Hawaii TANF State Plan states that a review of all eligibility requirements is required every 12 months for all TANF households. The State Plan also states that for the Department to make a decision regarding an applicant’s eligibility, an interview must be conducted with the applicant no later than forty-five (45) days after the application is received. Effect Failure to follow the established procedures in place over the eligibility determination process resulted in non-compliance with the requirement and questioned costs. Cause and View of Responsible Officials The Department has a history of backlogged cases, which does not allow them to work on current issues when they arise. Recommendation We recommend that the Department work with Administration for Children and Families to determine what remediation actions, if any, are required.
Condition We selected a non statistical sample of three subawards for testing and noted two subawards where the reporting required by the Federal Funding Accountability and Transparency Act (“FFATA”) was not completed. Criteria Under FFATA, the Department is required to report first-tier subawards of $30,000 or more by the end of the month following the month in which the obligation was made. Effect Failure to file required reports reduces transparency on the use of program funds and represents noncompliance with the requirements of 2 CFR Part 200. Cause and View of Responsible Officials There was a lack of diligence in following the Department’s established policies and procedures to ensure compliance with the requirements. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition We selected a non-statistical sample of 60 case files for testing and noted one instance where the Department’s records did not support the use of the income information obtained through the Income Eligibility and Verification System (“IEVS”) to evaluate or re-evaluate the benefit calculation. A similar finding was reported in the prior year as Finding No. 2024-012. Criteria Pursuant to 45 CFR 205.55, the Department is required to request through the IEVS system, wage information, unemployment compensation, Social Security Administration, unearned income, and any other income information. Effect Failure to properly use IEVS information to evaluate benefit amounts resulted in potential over payment of benefits. Cause and View of Responsible Officials There was a lack of diligence in following the Department’s established policies and procedures to ensure compliance with the requirements. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition During our audit, we selected a non-statistical sample of 60 individuals for testing out of a population of approximately 434,000 enrollments. The enrollments selected for testing represented approximately $286,000 of payments out of a total payment population of $2.1 billion. We identified one enrollment whose benefits were not timely terminated after failing to provide verification to support revalidation. A similar finding was reported in the prior year as Finding No. 2024-014. Criteria Title 42 CFR Part 435.912 requires the timely determination of eligibility of individuals who apply for Medicaid benefits within 1) 90 days for applicants who apply for Medicaid on the basis of disability (MAGI-excepted), and 2) 45 days for all other applicants (MAGI). In addition, Title 42 CFR Part 435.916 requires annual re-verifications of participant eligibility. Effect Failure to follow the established policies and procedures in place over the Medicaid eligibility determination process represents an instance of noncompliance with the requirements of 2 CFR Part 200, resulting in questioned costs. Cause and View of Responsible Officials Although the Department has policies and procedures in place requiring the maintenance of required documentation, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend the Department implement training and standard operating procedures to ensure eligibility determinations are completed in a timely manner.
Condition We selected a non-statistical sample of five grant awards and noted one instance where only 2.7% of program expenditures were made for improving the quality of care for infants and toddlers, which was below the required threshold of 3.0%. The Department’s expenditures for improving the quality of care for infants and toddlers were approximately $197,000 below the required amount. Criteria Pursuant to 45 CFR § 98.50(b)(2), no less than three percent of funds expended shall be used to carry out activities related to the quality of care for infants and toddlers. Effect Failure to spend the required earmarking requirement represents an instance of noncompliance with the requirements of 45 CFR § 98.50(b)(2). Cause and View of Responsible Officials There was a lack of diligence in following the Department’s established policies and procedures to ensure compliance with the requirements. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including those specified under Criteria above. Additionally, we recommend that the Department diligently comply with its policies and procedures.
Condition During our audit, we selected a non-statistical sample of 60 participant files which approximated $42,000 in monthly payments, out of a population of approximately 174,800 participant files which approximated $693 million in total annual benefit payments, for testing and noted exceptions in 10 case files as follows: • One case file where manually entered income and deduction amounts did not agree with the documentation retained in the participant’s case file. • Four case files where manually entered deduction amounts did not agree with the documentation retained in the participant’s case files. • One case file where manually entered income information did not agree with the documentation retained in the participant’s case file. • Two case files where the documentation did not show proper eligibility determination. • Two case files where the documentation did not show proper eligibility determination and manually entered income information did not agree with the documentation retained in the participant’s case file. A similar finding was reported in the prior year as Finding No. 2024-005. Criteria Pursuant to 7 CFR 272.10(b)(1)(i), the SNAP system should be efficiently automated to determine eligibility and calculate benefits or validate the eligibility worker’s calculations by processing and storing all case file information necessary for the eligibility determination and benefit computation (including but not limited to all household members’ names, addresses, dates of birth, social security numbers, individual household members’ earned and unearned income by source, deductions, resources, and household size). Effect Participants received more or did not receive the full amount of benefits they were eligible for, resulting in questioned costs. Cause and View of Responsible Officials There was a lack of diligence in following the Department’s established policies and procedures to ensure compliance with the requirements. Recommendation We recommend the Department emphasize the importance of diligently checking that any information entered manually agrees to the supporting documentation retained in the participant’s file. We also recommend the Department consider implementing a secondary review of participant files where information affecting the calculation of benefits is entered manually.
Condition During our audit, we selected a non-statistical sample of 60 daily reconciliations for testing and noted eight instances where variances were not investigated and there was no evidence that a review of the daily reconciliation was performed. The Department’s daily reconciliations identified variances totaling approximately $4.9 million. A similar finding was reported in the prior year as Finding No. 2024-004. Criteria Pursuant to 7 CFR 274.4, the Department is required to perform daily reconciliations of all SNAP transactions between the State’s Benefit Account, the US Treasury Department, and all the EBT contractors. Effect Failure to resolve the reconciling items resulted in non-compliance with the requirement. Cause and View of Responsible Officials Although the Department has policies and procedures in place regarding reviews, the policies and procedures do not explicitly require a supervisor sign-off documenting their review resulting in the inconsistent application and documentation of supervisor reviews. Recommendation We recommend that the Department develop procedures to ensure that identified variances are resolved and that the reconciliation is reviewed in a timely manner.
Condition We selected a non-statistical sample of three subrecipients and noted that in each case, the Department did not perform required during-the-award monitoring of its subrecipients. In addition, the Department did not verify that that subrecipients were audited if required by 2 CFR Part 200, Subpart F. Criteria Pursuant to 2 CFR 200.332(d), pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pursuant to 2 CFR 200.332(f), pass through entities must verify that subrecipients expected to be audited as required by 2 CFR Part 200, Subpart F, met this requirement. Effect Failure to monitor subrecipient activities or verify that subrecipients have completed their required Single Audits increases the risk that noncompliance at the subrecipient level goes undetected. Cause and View of Responsible Officials The issue occurred during a period of staff transition, during which roles were assumed without the benefit of documented procedures, formal training, or established prior practices. Recommendation We recommend that the Department establish formal written policies and procedures to ensure that the required during-the-award monitoring is performed and the required subrecipient Single Audit reports are obtained and reviewed, including appropriate follow up on any relevant audit findings.