2022-038 Department of Human Services Ensure work participation rate calculation uses verified and accurate data Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Yea...
2022-038 Department of Human Services Ensure work participation rate calculation uses verified and accurate data Federal Awarding Agency: U.S. Department of Health and Human Services Assistance Listing Number and Name: 93.558 Temporary Assistance for Needy Families Federal Award Numbers and Years: 2021G996115, 2021; 2022G996115, 2022 Compliance Requirement: Special Test and Provisions Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: 2021-010, 2020-014, 2019-009 Questioned Costs: N/A Criteria: 45 CFR 261.61-62, 65 Federal regulations require each state maintain adequate documentation, verification, and internal control procedures to ensure the accuracy of data used in calculating work participation rates. Each state must have procedures to count and verify reported hours of work and must comply with its Work Verification Plan as approved by the U.S. Department of Health and Human Services (DHHS). Oregon?s Work Verification Plan outlines a system of controls for how reported hours will be verified and documented, and for reviews and monitoring procedures to identify errors. Work participation hours are reported via the quarterly Temporary Assistance for Needy Families (TANF) ACF-199 data reports and for benefits paid with designated state funds called maintenance of effort (MOE), the ACF-209 reports. As stated in a separate finding, titled `Ensure performance data reports are complete and accurate,? we determined the data reports are not complete or accurate. However, we found the department did correct a previous issue in which work participation hours on the ACF-199 report were left blank. Although reports were known to be incomplete, we reviewed the reporting periods October 1, 2021, through June 30, 2022, to test for compliance of the Work Verification Plan. We reviewed 20 randomly selected ACF-199 cases from a population of 16,249, and 20 randomly selected ACF-209 cases from a population of 146,324 of participating clients for verification of work activity participation. We found: Five of 20 ACF-199 cases with reported participation hours did not agree with hours in the system of record TRACS. 14 of 20 ACF-199 cases lacked support for the reported hours. 9 of 20 ACF-209 cases lacked support for the reported hours. These inaccurate or unverified hours were reported to DHHS for use in calculating the work participation rate. If the state fails to follow the approved Work Verification Plan, DHHS may penalize the state. We recommend TANF program management ensure the work participation rate is calculated appropriately using verified and accurate participation data in adherence to the department?s Work Verification Plan. We also recommend program management review the system of controls and identify where improvements are needed to ensure compliance with the work verification plan. MANAGEMENT RESPONSE: We agree with this recommendation. The Department will develop training specific to error trends based on Quality Control audits of the JOBS program, skill enhancement/best practices on collecting and documenting accurate attendance, and technical training on the Department?s attendance documentation system, TRACS. The training will be instructor led and offered at minimum on a quarterly basis. The Department will review and edit tools, resources, and attendance logs to ensure compliance with the work verification plan. Updates made will be communicated to staff working with families receiving TANF. The Department will also form a workgroup to review the attendance documentation and case management system known as the Transition Referral and Client Self-Sufficiency (TRACS) system. The workgroup will make recommendations to developer, which will include system enhancements and edits to improve the process for staff. Anticipated Completion Date: April 30, 2024 Contact: Annette Palmer, TANF Program Manager