Responsible Person(s): Kristy Cardwell, Program Analyst and Department of Benefit Programs Corrective Action Planned: Benefit Programs acknowledges the deficiencies identified in Findings 1–6 related to monitoring documentation, supervisory oversight, and quality assurance controls. While monitoring...
Responsible Person(s): Kristy Cardwell, Program Analyst and Department of Benefit Programs Corrective Action Planned: Benefit Programs acknowledges the deficiencies identified in Findings 1–6 related to monitoring documentation, supervisory oversight, and quality assurance controls. While monitoring activities were generally performed, documentation and verification controls were not consistently applied. The following corrective actions have been implemented or are in progress to strengthen compliance, oversight, and accountability. Finding 1 - Benefit Programs did not confirm that program consultants selected and documented sampling units appropriately. As a result, 3 out of 20 locality reviews (15%) lacked sufficient documentation of sampling units, and 1 out of 20 reviews (5%) did not include the required number of sampled cases. Response and Corrective Action: Benefit Programs have reinforced sampling requirements and documentation standards with all program consultants. A standardized sampling methodology guide and checklist have been implemented to ensure: -Proper selection of sample units in accordance with established policy; -Clear documentation of the sampling universe, methodology, documented circumstances where sample is less than expected in the final sample selection; and -Verification that the required number of cases is selected prior to initiating the review. Sub-Recipient Coordinator procedures have been strengthened to require documented confirmation of sampling adequacy before the monitoring review progresses to completion. Finding 2 - Benefit Programs did not confirm that program consultants uploaded all required monitoring records to the data repository. As a result, Benefit Programs could not provide complete documentation for 6 out of 20 locality reviews (30%). Response and Corrective Action: A standardized monitoring documentation checklist has been implemented to identify all required documents that must be uploaded to the designated data repository. Program consultants are now required to complete and certify the checklist at the conclusion of each review. Sub-Recipient Coordinator to confirm that all required documentation has been uploaded before the review is formally closed. Periodic quality assurance reviews will be conducted to ensure ongoing compliance. Finding 3 - Benefit Programs did not confirm that program consultants provided timely notification to localities for the monitoring review. As a result, Benefit Programs could not provide this documentation for 1 out of 20 locality reviews (5%). Response and Corrective Action: A standardized notification template and tracking log have been implemented to ensure consistent and timely communication with localities. Program consultants are required to retain notification correspondence in the monitoring file and upload documentation to the platform. Sub-Recipient Coordinator will verify that advance notification was issued in accordance with policy and properly documented prior to the commencement of the review. Finding 4 - Benefit Programs did not ensure that program consultants issued the final monitoring review report for 1 out of 20 locality reviews (5%) and did not confirm that 2 out of 20 locality review reports (10%) included all required elements. Response and Corrective Action: Benefit Programs has updated the final report template to clearly outline all required elements. The monitoring tracking spreadsheet will be updated to include the names of all reports to be uploaded to the platform. The spreadsheet tracks report completion and distribution timelines. Sub-Recipient Coordinator will review all final monitoring reports to ensure completeness, accuracy, and inclusion of all required components. The coordinator will work with monitoring staff to obtain all required documentation. Finding 5 - Benefit Programs could not provide reasonable assurance that subrecipients complied with award requirements for 5 out of 20 locality reviews (25%) because program consultants did not maintain complete sampling documentation and final locality review reports. Response and Corrective Action: To strengthen reasonable assurance over subrecipient compliance, Benefit Programs will reinforce the existing controls: -Mandatory use of standardized sampling and reporting templates; -Required Sub-Recipient Coordinator review confirming completeness of documentation; -Enhanced documentation retention procedures within the centralized repository; and -Periodic internal quality assurance reviews to validate that monitoring files are complete and support conclusions reached. These measures are designed to ensure sufficient, appropriate documentation exists to support compliance determinations. Finding 6 - Benefit Programs did not confirm that program consultants fully documented corrective actions. As a result, 5 out of 20 locality reviews (25%) did not have complete corrective action documentation. Response and Corrective Action: Benefit Programs will have a corrective action tracking tool to document: -Identified findings; -Required corrective actions; -Responsible parties; -Target completion dates; and -Evidence of remediation. Program consultants are required to upload supporting documentation demonstrating corrective action completion. Sub-Recipient Coordinator will verify the adequacy of corrective action documentation and work with monitoring staff to address needed information. Follow-up emails will be used to ensure timely resolution and documented verification. Estimated Completion Date: 7/1/2025