Finding No. 2022 008: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.659 and COVID 19 ? 93.659 ? Adoption Assistance Award Number and Award Year: 2101HIADPT, 2201HIADPT Condition...
Finding No. 2022 008: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.659 and COVID 19 ? 93.659 ? Adoption Assistance Award Number and Award Year: 2101HIADPT, 2201HIADPT Condition We selected a non statistical sample of 60 case files which approximated $33,000 in monthly benefit payments, out of a population of approximately 2,500 case files which approximated $15.4 million in total annual benefit payments, for testing and noted exceptions in 38 case files as follows: ? 19 case files where the initial or modified adoption agreement was missing and therefore did not have any support for the amount of monthly assistance paid. ? 21 case files where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing. ? Eight case files where the ?difficulty of care? determination was missing and therefore did not have any support for the assistance amount paid. ? Eight case files where documentation of a child?s special needs was missing. ? Eight case files where the supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents was missing. ? One case file where documentation of monthly non-recurring expenses was missing. ? One case file where documentation regarding continuation of monthly subsidy payments after the child?s 18th birthday was missing. ? One case file where the final approval was granted to a household with an individual who was convicted of spousal abuse. ? Five case files where the adoption decree was missing from the case records. Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (CWS) will make a note in each specific case record identified in this audit explaining the audit findings, and ? secure current modified adoption agreements for the nineteen missing documents, ? locate missing clearances for the twenty-one cases or re-run them if not located, Note: Not all clearances are secured prior to placement; Federal Bureau of Investigations (FBI) clearances come later and are NOT required prior to placement in a ?provisionally licensed? home. ? document the need precipitating Difficulty of Care (DOC) determination for the 8 records, showing how DOC was calculated. i. ensure that the written Adoption Assistance Agreement (AAA) matches the calculations and amount in the payment system or update/modify the AAA as appropriate, ? secure documentation of child?s special needs for the eight cases, noting categorical eligibility qualification as special needs for children adopted from foster care. Note: Hawaii is in the process of developing its new Comprehensive Child Welfare Information System (CCWIS) and plans to use this system to automatically code children in foster care as meeting the eligibility criteria for special needs. ? secure a copy of the court order which specified that the child should not be returned home, i.e., the order containing the ?contrary to the child?s welfare? language for the eight cases, ? document monthly non-recurring expenses in the missing case, ? document the reason for continuation of monthly subsidy payments after the child?s eighteenth birthday in one case, ? research/review and document why final approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that AAA was inappropriately authorized, provide family with an adverse action notice discontinuing the AA and explaining the appeals process, ? Although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption, secure a copy of the five missing adoption decrees. Note: The adoption decree is NOT required for payment as the AAA must be entered prior to the finalization of an adoption. 2. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (MICU) within ninety days to ensure missing documentation has been secured and/or properly noted in record. ? Additionally, the MICU will complete a random AA audit review approximately six months later. i. MICU will share random audit findings with CWS Administrators. ii. CWS Administrators will take corrective action based on MICU audit findings. 3. CWS supervisors and Social Services Division (SSD) Staff Development Specialists will ensure that line staff are familiar with these policies and procedures through individual supervision meetings and work product review. ? Staff with errors identified in this audit, consistent errors identified during individual supervision meetings or through work product review will: i. be given coaching/supervisory support to correctly complete documentation, ii. be required to participate in refresher training on Title IV-E Foster Custody, which is offered three times a year with participation documented by Staff Development Office. iii. During this review between the supervisor and the staff, documentation in the case file, as well as Child Protective Services System (CPSS) coding and payments, will be examined for completeness and consistency. iv. Needed corrections will be made to the documents and/or CPSS, as identified in the monthly reviews. 4. In consultation with the Department of Accounting and General Services (DAGS), CWS will develop and implement a new AAA form which identifies payment amounts by age, informing families of the progression. This will eliminate the need for a new agreement when a child moves from one payment category to another, as they age. ? Should the standard AA amounts change, an addendum to this universal agreement will be sent to families noting the change(s). ? Once a new AAA form has been created, the Staff Development Office will update the AA training module to include this new form and offer the updated training in the regular training rotation. 5. At the next Management Leadership Team meeting, CWS Branch Administrators will share with staff the results of this audit, explaining the direct correlation between documentation (or lack thereof) and financial penalties to the State. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in one through five may be modified, based on input from CWS Administrators and/or focus/exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2023 Responding Officials: Kisha C. Raby, Social Services Division Program Development Administrator, Elladine Olevao, Social Services Division Child Welfare Social Services Manager, and Carolina Anagaran, Social Services Division Administrative Officer