Finding 1148370 (2024-001)

Finding: Allowable Activities & Allowable Costs and Eligibility Federal Assistance Listing Number 93.658 – Foster Care-Title IV-E Department of Health and Human Services, Passed-Through Colorado Department of Human Services Award Number – None Provided; Award Year 2024 Criteria or Specific Requirement: Funds may be expended for foster care maintenance payments on behalf of eligible children, in accordance with the Title IV-E agency’s foster care maintenance payment rate schedule and in accordance with 45 CFR section 1356.21, to individuals serving as foster family homes, to childcare institutions, or public/private child-placement or child-care agencies. In accordance with Code of Colorado Regulations (CCR) section 7.302.2, for each child, Jefferson County Human Services (JCHS) must have an agreement with the provider which details the daily maintenance payments. JCHS agreement to purchases services must be signed by the provider and JCHS. Additionally, in accordance with CCR section 7.301.3, the Family Services Plan shall be reviewed in conference with the caseworker and supervisor every 90 calendar days. Condition: During our testing, we noted the following:  Two instances out of 40 where there was no signed agreement in place to support revised maintenance payments following a child’s 9th birthday. The correct maintenance amount was paid to the provider in accordance with the state of Colorado rates published in IM-CW–2024-0028 and IM-CW-2023-0021.  One instance out of 40 where the required 90-day review was not completed on time. The review was conducted 15 days late. Questioned Costs: None. Context: We tested 40 foster care placements that received Title IV-E assistance for the year ended December 31, 2024, and noted the issues described above. The tested sample represented approximately $102,000 in benefits issued. The total population consisted of approximately $1.8 million in benefits issued to approximately 700 individuals. A non-statistical sampling methodology was used to select the sample. Effect: The absence of appropriate controls related to the above requirements increases the risk of incorrect maintenance payments or the provision of inappropriate services to clients. Cause: The state's foster care system did not automatically generate a notice that a new agreement to purchase services was needed based on the child's birthday. Additionally, JCHS lacks an effective control mechanism to proactively identify when a 90-day review is approaching or overdue. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations and maintenance payments. This includes evaluating the need for additional backup controls when relying on the state’s foster care system. Additionally, we recommend that JCHS submit help desk tickets to the state to report the system limitation regarding notifications for agreement updates based on a child's birthday. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.