Finding 1061291 (2021-016)

Material Weakness
Requirement
N
Questioned Costs
$1
Year
2021
Accepted
2024-08-22

AI Summary

  • Core Issue: The SNAP ADP system showed discrepancies in benefit amounts for 18% of tested cases, leading to questioned costs of $1,421.
  • Impacted Requirements: Noncompliance with OMB guidelines for automating SNAP operations, specifically in maintaining accurate income guidelines and benefit levels.
  • Recommended Follow-Up: Ensure the CNMI keeps updated income guidelines on file and that personnel review eligibility determinations thoroughly.

Finding Text

Finding No. 2021-016 Federal Agency: U.S. Department of Agriculture AL Program: 10.551/10.561 SNAP Cluster Federal Award No.: 7NM400NM5 Area: Special Tests and Provisions – ADP System for SNAP Questioned Costs: $1,421 Criteria: In accordance with the July 2021 OMB Compliance Supplement, State agencies are required to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing and transmitting information concerning SNAP. This includes (1) processing and storing all case file information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation of households that have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period; and (3) generating data necessary to meet federal and reconciliation reporting requirements. Condition: Of forty case files tested, aggregating $23,692 of a total population of $3.08M, the following were noted: 1. For seven (or 18%), the estimated benefit amount per the Maven Automated Data Processing (ADP) system differed from the estimated benefits per audit expectation based on the applicable FY 2021 maximum monthly benefit schedule compared to the amount reflected in the Maven ADP system, which pertain to the maximum amount for Fiscal Year 2022. Finding No. 2021-016, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.551/10.561 SNAP Cluster Federal Award No.: 7NM400NM5 Area: Special Tests and Provisions – ADP System for SNAP Questioned Costs: $1,421 Conditions, continued: 2. For one (or 3%), inconsistencies between the adjudicator’s maximum allotment per income threshold ($708 reflecting October 1, 2020 maximum) and the Maven ADP system ($1,002 reflecting February 1, 2021 maximum) were noted for Record ID B100081068, certified from 12/01/20 to 02/28/21, resulting in a variance of $294 between the estimated benefit amount per the Maven ADP system and per audit expectation, for which the amount is questioned. 3. For one (or 3%), inconsistencies between the adjudicator’s maximum allotment per income threshold ($389 reflecting October 1, 2020 maximum) and the Maven ADP system ($551 reflecting February 1, 2021 maximum) were noted for Record ID B100082118, certified from 01/01/21 to 03/31/21, resulting into a variance of $162 between the estimated benefit amount per Maven ADP system and per audit expectation, for which the amount is questioned. Cause: The applicable monthly income level schedule used covering FY 2021 was not on file. Effect: CNMI is in noncompliance with applicable Special Tests and Provisions - ADP System for SNAP requirements, and questioned costs of $1,421 result as the projected questioned costs exceed the $25,000 threshold. Recommendation: As the Maven ADP System automatically updates income guidelines and benefit levels, we recommend that the CNMI maintains on file the applicable income guidelines and benefit levels used for eligibility determinations and that the CNMI responsible personnel should thoroughly review eligibility determinations. Finding No. 2021-016, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.551/10.561 SNAP Cluster Federal Award No.: 7NM400NM5 Area: Special Tests and Provisions – ADP System for SNAP Questioned Costs: $1,421 Views of Responsible Officials: Condition 1 - The CNMI-NAP disagrees with this finding. NAP staff has to guide the auditors during the time the audit is being performed to understand the history and process of files being audited. Case ID#B100092775 variance of $69 caused by change in income guideline and benefit level effective October 1st 2020 income level is 781 benefit for Saipan is $221. Corrective action taken by Eligibility worker processed income for household of 1 as SSI which gave household $41 benefit. Income should be counted as SSA which at the time the adjustment was made and increased the benefit amount for the household. Case ID#B100094249 variance of $180 a change in income and benefit level. Household income was $108 which changed to $120 for a household of 4. Adjustment was made to reflect changes including benefit level. From $708.00 to $1,231. Case ID #B100095019 variance of $69. Benefit level was $212, and household had $20 contribution as unearned income. Benefit issued was 295 new benefit level effective October 1st, 2021 adjusted benefit issuance at $364 (maximum benefit for household of one for zero income is $369). Case ID#B100095077 variance of $180. Benefit for household of 3 was issued for 2020 benefit and income level. November benefit effectuated new income and benefit level. Issued benefit is based by household and income of head of household. Case ID#B100094664 Variance of $69. Household is zero income maximum benefit level issued was $300 reflecting 2020 benefit level. On October 1st, 2021 eligibility system automatically adjust benefit to $369 as per new benefit level. Case ID#B10109695 variance of $126 household of 2 maximum benefit was $389 with ineligible household members earning SS benefits totaling at $167 (prorated income) benefit issued was $651. Increase in benefit and income level was automatically adjusted by the eligibility system. Finding No. 2021-016, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.551/10.561 SNAP Cluster Federal Award No.: 7NM400NM5 Area: Special Tests and Provisions – ADP System for SNAP Questioned Costs: $1,421 Views of Responsible Officials, continued: Case ID#B100093732 Variance of 272 household of 5 maximum Benefit level for zero income Household is $1,462 deduction of 25 percent for over issuance ($272) increase of benefit level automatically adjusted by Eligibility system and still taking offset of 25% for over issued benefits. Over issuance claim is already paid off. Condition 2 - The CNMI-NAP disagrees with this finding. NAP staff has to guide the auditors during the time the audit is being performed to understand the history and process of files being audited. Case ID#B100081068 Questioned cost of $294. Head of household declared zero income. Benefit amount under issued in the amount of $229 by eligibility system for maximum level of benefits should be $1,231. Unable to do corrective action due to beyond 2 months from time the discrepancy was found: Corrective action for eligibility system to implement a system audit that will prevent future glitches that would create a loss for both the household and NAP program budget. Condition 3 - The CNMI-NAP disagrees with this finding. NAP staff has to guide the auditors during the time the audit is being performed to understand the history and process of files being audited. Case ID#B100082118 questioned cost is $162 household had income from ineligible parents which is prorated towards the two eligible household members. Total prorated unearned income is $843 which was counted towards the household’s benefits. Then household became zero income due to Furlough from COVID-19 pandemic. We disagree with the findings. When the auditor reviewed the case files, there was a misunderstanding of changes in household composition and income which is also affected by the increase in income guidelines and benefit levels between the certification period. This created the variances that the auditor noted in the findings. *CNMI NAP recommends having NAP staff guide the auditor during time the audit is being performed to understand history and process of files being audited. Finding No. 2021-016, continued Federal Agency: U.S. Department of Agriculture AL Program: 10.551/10.561 SNAP Cluster Federal Award No.: 7NM400NM5 Area: Special Tests and Provisions – ADP System for SNAP Questioned Costs: $1,421 Views of Responsible Officials, continued: CNMI-NAP recently hired a Certification Unit Supervisor who had been on board for close to three months. He had been actively working closely with the EWs and especially the Management Evaluation Unit (MEU) who oversees the program reviews and quality control. Mini Trainings and assessments of the Certification Unit are in the works. One training was done sometimes in April by the MEU to ensure compliance is met. More trainings and workshops are in being planned between the Certification Unit and Management Evaluation Unit for a better process and procedures. Auditor Response: Condition 1 – The applicable benefit level used for eligibility determination was not provided. Condition 2 – The CNMI acknowledges the discrepancy and planned on a corrective action to prevent future system glitches. Condition 3 – Documentation supporting the change in household composition and income were not provided.

Categories

Questioned Costs Eligibility Special Tests & Provisions Reporting

Other Findings in this Audit

  • 484842 2021-012
    Significant Deficiency
  • 484843 2021-013
    Significant Deficiency Repeat
  • 484844 2021-014
    Material Weakness
  • 484845 2021-012
    Significant Deficiency
  • 484846 2021-013
    Significant Deficiency Repeat
  • 484847 2021-014
    -
  • 484848 2021-015
    Material Weakness
  • 484849 2021-016
    Material Weakness
  • 484850 2021-014
    Material Weakness
  • 484851 2021-016
    Material Weakness
  • 484852 2021-014
    Material Weakness
  • 484853 2021-017
    Material Weakness
  • 484854 2021-018
    Material Weakness Repeat
  • 484855 2021-019
    Significant Deficiency
  • 484856 2021-020
    Material Weakness Repeat
  • 484857 2021-021
    Significant Deficiency
  • 484858 2021-022
    Material Weakness Repeat
  • 484859 2021-023
    Material Weakness Repeat
  • 484860 2021-017
    Material Weakness
  • 484861 2021-018
    Material Weakness Repeat
  • 484862 2021-019
    Significant Deficiency
  • 484863 2021-020
    Material Weakness Repeat
  • 484864 2021-021
    Significant Deficiency
  • 484865 2021-022
    Material Weakness Repeat
  • 484866 2021-023
    Material Weakness Repeat
  • 484867 2021-017
    Material Weakness
  • 484868 2021-018
    Material Weakness Repeat
  • 484869 2021-019
    Significant Deficiency
  • 484870 2021-020
    Material Weakness Repeat
  • 484871 2021-021
    Significant Deficiency
  • 484872 2021-022
    Material Weakness Repeat
  • 484873 2021-023
    Material Weakness Repeat
  • 484874 2021-017
    Material Weakness
  • 484875 2021-018
    Material Weakness Repeat
  • 484876 2021-019
    Significant Deficiency
  • 484877 2021-020
    Material Weakness Repeat
  • 484878 2021-021
    Significant Deficiency
  • 484879 2021-022
    Material Weakness Repeat
  • 484880 2021-023
    Material Weakness Repeat
  • 484881 2021-017
    Material Weakness
  • 484882 2021-018
    Material Weakness Repeat
  • 484883 2021-019
    Significant Deficiency
  • 484884 2021-020
    Material Weakness Repeat
  • 484885 2021-021
    Significant Deficiency
  • 484886 2021-022
    Material Weakness Repeat
  • 484887 2021-023
    Material Weakness Repeat
  • 484888 2021-024
    Material Weakness Repeat
  • 484889 2021-025
    Significant Deficiency Repeat
  • 484890 2021-024
    Material Weakness Repeat
  • 484891 2021-025
    Significant Deficiency Repeat
  • 484892 2021-026
    Material Weakness Repeat
  • 484893 2021-027
    Significant Deficiency Repeat
  • 484894 2021-028
    Material Weakness
  • 484895 2021-029
    Significant Deficiency
  • 484896 2021-030
    Significant Deficiency
  • 484897 2021-031
    Material Weakness
  • 484898 2021-032
    Material Weakness
  • 484899 2021-033
    Material Weakness
  • 484900 2021-034
    Significant Deficiency Repeat
  • 484901 2021-035
    Material Weakness Repeat
  • 484902 2021-034
    Significant Deficiency Repeat
  • 484903 2021-035
    Material Weakness Repeat
  • 484904 2021-034
    Significant Deficiency Repeat
  • 484905 2021-035
    Material Weakness Repeat
  • 484906 2021-036
    Material Weakness Repeat
  • 484907 2021-037
    Material Weakness
  • 484908 2021-038
    Material Weakness
  • 484909 2021-039
    Significant Deficiency
  • 484910 2021-038
    Material Weakness
  • 484911 2021-039
    Significant Deficiency
  • 484912 2021-040
    Material Weakness
  • 484913 2021-041
    Material Weakness
  • 484914 2021-042
    Material Weakness
  • 1061284 2021-012
    Significant Deficiency
  • 1061285 2021-013
    Significant Deficiency Repeat
  • 1061286 2021-014
    Material Weakness
  • 1061287 2021-012
    Significant Deficiency
  • 1061288 2021-013
    Significant Deficiency Repeat
  • 1061289 2021-014
    -
  • 1061290 2021-015
    Material Weakness
  • 1061292 2021-014
    Material Weakness
  • 1061293 2021-016
    Material Weakness
  • 1061294 2021-014
    Material Weakness
  • 1061295 2021-017
    Material Weakness
  • 1061296 2021-018
    Material Weakness Repeat
  • 1061297 2021-019
    Significant Deficiency
  • 1061298 2021-020
    Material Weakness Repeat
  • 1061299 2021-021
    Significant Deficiency
  • 1061300 2021-022
    Material Weakness Repeat
  • 1061301 2021-023
    Material Weakness Repeat
  • 1061302 2021-017
    Material Weakness
  • 1061303 2021-018
    Material Weakness Repeat
  • 1061304 2021-019
    Significant Deficiency
  • 1061305 2021-020
    Material Weakness Repeat
  • 1061306 2021-021
    Significant Deficiency
  • 1061307 2021-022
    Material Weakness Repeat
  • 1061308 2021-023
    Material Weakness Repeat
  • 1061309 2021-017
    Material Weakness
  • 1061310 2021-018
    Material Weakness Repeat
  • 1061311 2021-019
    Significant Deficiency
  • 1061312 2021-020
    Material Weakness Repeat
  • 1061313 2021-021
    Significant Deficiency
  • 1061314 2021-022
    Material Weakness Repeat
  • 1061315 2021-023
    Material Weakness Repeat
  • 1061316 2021-017
    Material Weakness
  • 1061317 2021-018
    Material Weakness Repeat
  • 1061318 2021-019
    Significant Deficiency
  • 1061319 2021-020
    Material Weakness Repeat
  • 1061320 2021-021
    Significant Deficiency
  • 1061321 2021-022
    Material Weakness Repeat
  • 1061322 2021-023
    Material Weakness Repeat
  • 1061323 2021-017
    Material Weakness
  • 1061324 2021-018
    Material Weakness Repeat
  • 1061325 2021-019
    Significant Deficiency
  • 1061326 2021-020
    Material Weakness Repeat
  • 1061327 2021-021
    Significant Deficiency
  • 1061328 2021-022
    Material Weakness Repeat
  • 1061329 2021-023
    Material Weakness Repeat
  • 1061330 2021-024
    Material Weakness Repeat
  • 1061331 2021-025
    Significant Deficiency Repeat
  • 1061332 2021-024
    Material Weakness Repeat
  • 1061333 2021-025
    Significant Deficiency Repeat
  • 1061334 2021-026
    Material Weakness Repeat
  • 1061335 2021-027
    Significant Deficiency Repeat
  • 1061336 2021-028
    Material Weakness
  • 1061337 2021-029
    Significant Deficiency
  • 1061338 2021-030
    Significant Deficiency
  • 1061339 2021-031
    Material Weakness
  • 1061340 2021-032
    Material Weakness
  • 1061341 2021-033
    Material Weakness
  • 1061342 2021-034
    Significant Deficiency Repeat
  • 1061343 2021-035
    Material Weakness Repeat
  • 1061344 2021-034
    Significant Deficiency Repeat
  • 1061345 2021-035
    Material Weakness Repeat
  • 1061346 2021-034
    Significant Deficiency Repeat
  • 1061347 2021-035
    Material Weakness Repeat
  • 1061348 2021-036
    Material Weakness Repeat
  • 1061349 2021-037
    Material Weakness
  • 1061350 2021-038
    Material Weakness
  • 1061351 2021-039
    Significant Deficiency
  • 1061352 2021-038
    Material Weakness
  • 1061353 2021-039
    Significant Deficiency
  • 1061354 2021-040
    Material Weakness
  • 1061355 2021-041
    Material Weakness
  • 1061356 2021-042
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
17.225 Unemployment Insurance $128.26M
97.030 Community Disaster Loans $93.73M
21.027 Coronavirus State and Local Fiscal Recovery Funds $67.34M
93.778 Medical Assistance Program $65.25M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $30.43M
21.019 Coronavirus Relief Fund $25.07M
10.539 Cnmi Nutrition Assistance $14.00M
93.767 Children's Health Insurance Program $10.91M
97.050 Presidential Declared Disaster Assistance to Individuals and Households - Other Needs $5.46M
10.542 Pandemic Ebt Food Benefits $5.14M
93.575 Child Care and Development Block Grant $4.48M
21.023 Emergency Rental Assistance Program $4.15M
15.875 Economic, Social, and Political Development of the Territories $3.86M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $3.31M
97.039 Hazard Mitigation Grant $2.64M
66.600 Environmental Protection Consolidated Grants for the Insular Areas - Program Support $2.39M
12.617 Economic Adjustment Assistance for State Governments $2.38M
20.205 Highway Planning and Construction $1.98M
93.434 Every Student Succeeds Act/preschool Development Grants $1.79M
97.U00 Usdhs Unknown $1.72M
64.203 State Cemetery Grants $1.67M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $1.51M
20.509 Formula Grants for Rural Areas and Tribal Transit Program $1.40M
11.419 Coastal Zone Management Administration Awards $1.35M
15.605 Sport Fish Restoration Program $1.33M
11.016 Statistical, Research, and Methodology Assistance $1.24M
17.277 Workforce Investment Act (wia) National Emergency Grants $1.11M
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $1.06M
15.611 Wildlife Restoration and Basic Hunter Education $927,077
97.012 Boating Safety Financial Assistance $792,755
90.404 2018 Hava Election Security Grants $768,969
20.500 Federal Transit_capital Investment Grants $710,984
20.600 State and Community Highway Safety $689,234
16.034 Coronavirus Emergency Supplemental Funding Program $682,825
16.588 Violence Against Women Formula Grants $588,272
97.067 Homeland Security Grant Program $557,543
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $472,931
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $435,053
15.615 Cooperative Endangered Species Conservation Fund $428,349
93.568 Low-Income Home Energy Assistance $411,238
93.630 Developmental Disabilities Basic Support and Advocacy Grants $330,830
93.489 Child Care Disaster Relief (a) $323,887
81.041 State Energy Program $306,658
11.482 Coral Reef Conservation Program $297,572
66.801 Hazardous Waste Management State Program Support $271,746
20.218 National Motor Carrier Safety $271,490
17.235 Senior Community Service Employment Program $264,350
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $257,565
17.504 Consultation Agreements $251,520
10.649 Pandemic Ebt Administrative Costs $239,859
81.042 Weatherization Assistance for Low-Income Persons $237,586
93.556 Promoting Safe and Stable Families $237,486
17.259 Wia Youth Activities $220,884
93.590 Community-Based Child Abuse Prevention Grants $186,057
12.002 Procurement Technical Assistance for Business Firms $184,985
93.569 Community Services Block Grant $174,616
17.258 Wia Adult Program $164,131
15.904 Historic Preservation Fund Grants-in-Aid $163,122
15.634 State Wildlife Grants $162,939
16.710 Public Safety Partnership and Community Policing Grants $158,140
10.664 Cooperative Forestry Assistance $143,503
16.738 Edward Byrne Memorial Justice Assistance Grant Program $142,873
16.750 Support for Adam Walsh Act Implementation Grant Program $138,057
45.310 Grants to States $120,692
93.052 National Family Caregiver Support, Title Iii, Part E $120,096
17.278 Wia Dislocated Worker Formula Grants $115,236
11.472 Unallied Science Program $111,511
93.464 Acl Assistive Technology $110,282
10.766 Community Facilities Loans and Grants $104,997
11.437 Pacific Fisheries Data Program $95,986
11.307 Economic Adjustment Assistance $94,707
15.663 Nfwf-Usfws Conservation Partnership $86,002
59.061 State Trade and Export Promotion Pilot Grant Program $79,669
10.170 Specialty Crop Block Grant Program - Farm Bill $78,903
10.551 Supplemental Nutrition Assistance Program $75,637
17.285 Apprenticeship USA Grants $71,713
11.549 State and Local Implementation Grant Program $65,103
66.040 State Clean Diesel Grant Program $64,655
11.467 Meteorologic and Hydrologic Modernization Development $64,198
84.177 Rehabilitation Services_independent Living Services for Older Individuals Who Are Blind $56,288
17.273 Temporary Labor Certification for Foreign Workers $49,847
93.643 Children's Justice Grants to States $48,685
93.667 Social Services Block Grant $45,906
93.127 Emergency Medical Services for Children $45,368
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $43,594
16.017 Sexual Assault Services Formula Program $39,063
45.129 Promotion of the Humanities_federal/state Partnership $34,242
93.669 Child Abuse and Neglect State Grants $33,144
93.369 Acl Independent Living State Grants $33,059
15.916 Outdoor Recreation_acquisition, Development and Planning $32,030
11.U01 Joint Enforcement Agreement $29,826
93.053 Nutrition Services Incentive Program $29,791
11.454 Unallied Management Projects $25,037
10.680 Forest Health Protection $24,576
15.954 National Park Service Conservation, Protection, Outreach, and Education $24,461
45.025 Promotion of the Arts_partnership Agreements $24,399
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $21,482
93.747 Elder Abuse Prevention Interventions Program $19,666
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $17,609
11.407 Interjurisdictional Fisheries Act of 1986 $15,800
97.042 Emergency Management Performance Grants $12,049
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $11,980
16.585 Drug Court Discretionary Grant Program $10,004
17.600 Mine Health and Safety Grants $8,153
93.612 Native American Programs $7,951
11.U02 Unknown $7,719
93.645 Stephanie Tubbs Jones Child Welfare Services Program $7,457
59.037 Small Business Development Centers $6,134
20.514 Public Transportation Research $5,956
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $5,350
10.025 Plant and Animal Disease, Pest Control, and Animal Care $5,049
12.113 State Memorandum of Agreement Program for the Reimbursement of Technical Services $4,791
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $2,041
97.047 Pre-Disaster Mitigation $1,699
10.179 Micro-Grants for Food Security Program $147
16.575 Crime Victim Assistance $-2,960