Finding 1156121 (2024-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-09-29
Audit: 368538
Organization: Clay County (MN)

AI Summary

  • Core Issue: Incomplete documentation and incorrect input in METS led to significant deficiencies in verifying Medicaid eligibility.
  • Impacted Requirements: Compliance with federal regulations on internal controls and eligibility verification for Medicaid participants was not met.
  • Recommended Follow-Up: Clay County should enhance procedures and training to ensure all necessary documentation is accurately managed in METS.

Finding Text

2024-002 Eligibility - METS Prior Year Finding Number: 2023-002 Year of Finding Origination: 2023 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Significant Deficiency and Other Matter Federal Agency: U.S. Department of Health and Human Services Program: 93.778 Medical Assistance Program Award Number and Year: 2405MN5ADM; 2024 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 42 U.S. Code of Federal Regulations §§ 435.911 and 435.945 require the state Medicaid agency to determine and verify eligibility of enrollees in Medicaid. The Minnesota Department of Human Services provides the Minnesota Health Care Programs Eligibility Policy Manual. The manual contains the Minnesota Department of Human Services eligibility policies for the Minnesota Health Care Programs, including the eligibility requirements of Medical Assistance. Specific eligibility requirements are included for participants’ citizenship verification and income limits. Minnesota Statutes, section 256B.05 requires county agencies to administer Medical Assistance. Condition: The Minnesota Department of Human Services maintains the computer systems, METS, which is used by Clay County to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation to support participant eligibility was available or input correctly. The following exceptions were noted in a sample of 40 case files: • One case file lacked citizenship documentation. • One case file did not document the participant’s income correctly. Questioned Costs: Not applicable. Clay County administers the program, but the State of Minnesota pays benefits to participants in this program. Context: The State of Minnesota and Clay County split the eligibility determination process. Generally, Clay County resolves eligibility issues when prompted by the system, while the State performs the initial review of the case files, including determining the information in METS is verified. Participants receive benefits from the State. The population consisted of 17,456 active METS case files in the Medical Assistance Program in 2024; the sample size was 40 case files. The sample size was based on the guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: The improper input or updating of information in METS and lack of verification of key eligibility-determining factors increase the risk that program participants will receive benefits when they are not eligible. Cause: Program personnel responsible for resolving eligibility issues in METS did not ensure all required information was input or updated correctly or verified. Recommendation: We recommend Clay County implement additional procedures to provide reasonable assurance that all documentation needed to resolve eligibility issues exists and program personnel properly input, update, or verify the documentation in METS. In addition, Clay County should consider providing further training to program personnel. View of Responsible Official: Concur

Corrective Action Plan

Finding Number: 2024-002 Finding Title: Eligibility - METS Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Quinn Jaeger, Social Services Director Mikala Wodarek, Social Services Supervisor Corrective Action Planned: Clay County Social Services acknowledges the audit finding that in 2 of the 40 METS Medical Assistance eligibility case files reviewed, required documentation was either missing or not properly recorded. To address this, all eligibility workers will receive refresher training on documentation standards, with a focus on citizenship and income verification requirements. The lead worker for this program will conduct random case reviews monthly, in addition to 3 case reviews for each worker around their annual performance evaluation. These case reviews will be reviewed with the worker thoroughly, coaching provided if necessary, and any errors found will be corrected. The supervisor will retain these case reviews and analyze them for patterns and provide team training and guidance as appropriate. For staff with repeated errors, performance management will be enacted in the form of verbal coaching, performance improvement plans, etc. In addition, annual training on eligibility documentation, specifically around citizenship status, will be added to the Division's training plan. Progress will be tracked through internal audits and summarized for leadership review. These actions are intended to ensure all required documentation is properly obtained, verified, and recorded in METS, thereby strengthening internal controls, reducing the risk of ineligible individuals receiving benefits, and improving future audit compliance. Anticipated Completion Date: Refresher training for eligibility workers and thorough review of 2024 audit findings both individually and as a group: completed on August 7, 2025 Case reviews by lead worker: Already implemented at the time of this writing and ongoing Review and reporting to leadership: Beginning January 1, 2026 and ongoing Annual training incorporated into department plan: Effective December 1, 2025

Categories

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1156122 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $6.94M
93.563 Child Support Services $1.33M
93.558 Temporary Assistance for Needy Families $1.29M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $736,074
93.658 Foster Care Title IV-E $695,692
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $436,256
93.667 Social Services Block Grant $357,779
16.738 Edward Byrne Memorial Justice Assistance Grant Program $204,298
93.959 Block Grants for Prevention and Treatment of Substance Abuse $175,490
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $136,335
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $104,974
10.555 National School Lunch Program $93,434
21.032 Covid-19 - Local Assistance and Tribal Consistency Fund $79,577
93.069 Public Health Emergency Preparedness $79,188
93.994 Maternal and Child Health Services Block Grant to the States $77,558
93.991 Preventive Health and Health Services Block Grant $61,316
10.553 School Breakfast Program $50,893
16.575 Crime Victim Assistance $50,581
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $48,623
93.958 Block Grants for Community Mental Health Services $40,694
93.575 Child Care and Development Block Grant $38,960
97.042 Emergency Management Performance Grants $37,714
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $33,011
93.268 Immunization Cooperative Agreements $19,374
93.778 Medical Assistance Program $18,268
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $15,516
93.590 Community-Based Child Abuse Prevention Grants $11,670
93.556 Marylee Allen Promoting Safe and Stable Families Program $10,817
20.600 State and Community Highway Safety $6,073
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $5,097
93.645 Stephanie Tubbs Jones Child Welfare Services Program $4,627
21.U01 Joint Law Enforcement Operation Task Force Project $3,221
84.181 Special Education-Grants for Infants and Families $2,875
10.572 Wic Farmers' Market Nutrition Program (fmnp) $1,175
93.767 Children's Health Insurance Program $1,139
93.008 Medical Reserve Corps Small Grant Program $580