Finding Text
Finding No. 2024 006: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness)
Questioned cost: $ 18,613
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:
2301HIADPT 2023
2401HIADPT 2024
Repeat Finding? Yes
Condition
We selected a non statistical sample of 60 case files which approximates $54,700 in monthly benefit payments, out of a population of approximately 1,359 case files which approximate $12.2 million in total annual benefit payments, for testing and noted exceptions in 33 case files as follows:
• Thirteen 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.
• One case in which the payment was improperly loaded in the system causing a difference between the agreement amount and paid amount.
• Six case files where the “difficulty of care” determination was missing and therefore did not have any support for the assistance amount paid.
• Thirteen case files where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing.
• Seven 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.
• Three 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. 2023 008.
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 675(3), the agreement for the adoption subsidy must be signed before the final decree of adoption and contain the information concerning the nature of services.
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), the State must determine whether the child cannot or should not be returned to the home of his or her parents.
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 instances 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 the Criteria section above. Additionally, we recommend that the Department diligently comply with its policies and procedures.