FAC Explorer

Finding 1161192 (2022-012)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
$1
Year
2022
Accepted
2025-10-22
Audit: 371187
Organization: Commonwealth of the Northern Mariana Islands (MP)
Auditor: ERNST & YOUNG (CNMI) INC

AI Summary

  • Core Issue: CNMI did not provide necessary documentation to support eligibility for $58,494 in P-EBT benefits, leading to noncompliance with federal requirements.
  • Impacted Requirements: Eligibility criteria outlined in the approved State Plan were not followed, including maintaining accurate records of beneficiaries and ensuring proper access for audits.
  • Recommended Follow-Up: Establish monitoring controls to maintain eligibility data and improve coordination between CNMI NAP and eligibility workers for future audits.

Finding Text

Finding No. 2022-012 Federal Agency: U.S. Department of Agriculture AL Program: 10.542 Pandemic EBT Food Benefits (P-EBT) Federal Award No.: 7NM400NM2 Area: Eligibility Questioned Costs: $58,494 Criteria: Per Sections 3(a) and 4(a) of the CNMI State Plan for Pandemic EBT, a child is eligible for P-EBT benefits if two conditions are met: 1. The child would be eligible for free or reduced-price meals if the National School Lunch Program and School Breakfast Program were operating normally. This includes children who are: a. Directly certified or determined “other source categorically eligible” for SY 2020-2021, or b. Certified through submission of a household application processed by the child’s school district for SY 2020-2021, or c. Enrolled in a Community Eligibility Provision school or a school operating under Provisions 2 or 3, or d. Directly certified, determined other source categorically eligible, or certified by application in SY 2019-2020 and the school district has not made a new school meal eligibility determination for the child in SY 2020-2021. The date range covered by the State plan for children in school is from August 10, 2020 to June 11,2021 and from October 1, 2020 to June 11, 2021 for children in child care. 2. The child does not receive free or reduced-price meals at the school because the school is closed or has been operating with reduced attendance or hours for at least 5 consecutive days in the current school year. Once the minimum 5 consecutive day threshold is met, children are eligible to receive P-EBT benefits for closures or reductions in hours due to COVID-19. 3. Non-Federal entity’s records/database should include all individuals receiving benefits during the audit period. 4. Non-Federal entity must follow the eligibility process described in its approved State Plan. Condition: 1. Of sixty (or 100%) eligibility case files tested, aggregating $58,494 in total benefits paid of a total population of $5,980,039, documentation supporting eligibility were not provided. 2. We were not provided a complete listing of individuals that received benefits in FY2022. Cause: CNMI did not enforce compliance with applicable eligibility requirements and lacks monitoring control over the following: 1. Listing of validated eligibility roster data that were not uploaded into the Maven eligibility system due to data entry capacity limitation were not being maintained; and 2. Auditors’ access to selected case files for testing were not coordinated with the CNMI NAP eligibility workers and with the PSS-CNP office. Accordingly, CNMI NAP was unable to substantiate that selected case files were eligible to receive P-EBT benefits and that the eligibility process described in its approved State Plan were followed. Effect: The CNMI is in noncompliance with the applicable eligibility requirements and questioned costs of $58,494 result for Condition 1. Identification as a Repeat Finding: Finding No. 2021-015 Recommendation: We recommend the CNMI establish and implement monitoring internal control procedures over the following: 1. Maintain a listing of validated eligibility roster data case files that were not uploaded into the Maven system due to data entry capacity limitations; and 2. CNMI NAP personnel should coordinate with its eligibility workers and the PSS-CNP Office for auditors to access selected case files for testing. Views of Responsible Officials: Conditions 1 and 2 - CNMI NAP disagrees. CNMI NAP was informed that this finding had been cleared so we are perplexed as to the re-emergence of this audit finding. CNMI NAP contends that: 1. Eligibility for P-EBT benefits is not determined by CNMI NAP. P-EBT eligibility was determined by identifying children who qualified for free or reduced-price school meals and then correlating that with a reduction of in-person schooling due to COVID-19. Children in households receiving Supplement Nutrition Assistance Program (SNAP) and young children, under age six, were also eligible, provided their schools or childcare facilities closed or reduced hours for at least five consecutive days due to the pandemic. This data was provided by PSS, as well as the listing of eligible children that corresponded to this data set. 2. There are no “validated eligibility roster data case files” that were not uploaded into MAVEN due to data entry capacity limitations. All rosters provided by PSS were uploaded into MAVEN as this is the only way a case file can be generated in the system. 3. CNMI NAP has reconciled all benefits issued, including the P-EBT benefits for the audit year in question. This is a mandatory, non-negotiable process. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: Condition 1 - We understand that eligibility determination is being performed by PSS-CNP, for which in the beginning of the audit and during our fieldwork, we had communicated with CNMI NAP’s personnel to coordinate audit request for eligibility testing with PSS-CNP. This was again communicated with CNMI NAP’s personnel on June 9, 2025. In addition, in response to our follow up on June 19, 2025 of the pending eligibility case files, we were informed that CNMI NAP has yet to reach out to the point of contact at PSS-CNP. Further, in regard to the SNAP case files being maintained by CNMI NAP office, we were informed that the listing has been forwarded to have CNMI NAP’s EW team to assist in gathering the case files. However, case files were not made available for our examination and there was also no communication on our part that finding had been cleared. Condition 2 - Based on discussion with CNMI NAP’s personnel related to the variance of $4,387,281 noted between the program’s project expenditures report amounting to $10,367,320 and the benefits eligibility listing amounting to $5,980,039, it is our understanding from the discussion that the variance is due to expenditures for distributed coupons are recorded when coupons are redeemed and that some benefits were not included in the benefits listing due to data entry capacity limitation of the Maven eligibility system. We acknowledge the process of when expenditures are being recorded; however, there was no communication on our part that finding had been cleared but rather, we requested for the FY2021 listing of issued benefits to verify if the variance is accounted for; but the listing was not provided. We also acknowledge CNMI NAP’s reconciliation process, wherein total amount of coupons redeemed were being reconciled to CNMI NAP’s records. However, CNMI NAP was not able to identify which case files are part of the $4,387,281 variance as reconciliation is not based on individual coupons but rather by total amount redeemed.

Corrective Action Plan

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting eligibility determinations were not provided. Finding further states that CNMI NAP lacks monitoring control over the listing of validated eligibility roster data that were not uploaded into MAVEN eligibility system due to data entry capacity limitations (sic) were not being maintained; and Distributed coupons were not reconciled to the recorded expenditures for redeemed coupons. The resulting effect being that CNMI NAP is in noncompliance with the applicable eligibility requirements and questioned costs for condition 1. CNMI NAP was informed that this finding had been cleared so we are perplexed as to the re-emergence of this audit finding. CNMI NAP contends that: 1. Eligibility for P-EBT benefits is not determined by CNMI NAP. P-EBT eligibility was determined by identifying children who qualified for free or reduced-price school meals and then correlating that with a reduction of in-person schooling due to COVID-19. Children in households receiving SNAP and young children, under age six, were also eligible, provided their schools or childcare facilities closed or reduced hours for at least five consecutive days due to the pandemic. This data was provided by PSS, as well as the listing of eligible children that corresponded to this data set. 2. There are no “validated eligibility roster data case files” that were not uploaded into MAVEN due to data entry capacity limitations. All rosters provided by PSS were uploaded into MAVEN as this is the only way a case file can be generated in the system. 3. CNMI NAP has reconciled all benefits issued, including the P-EBT benefits for the audit year in question. This is a mandatory, non-negotiable process. Proposed Completion Date: Ongoing

Categories

Questioned Costs School Nutrition Programs Matching / Level of Effort / Earmarking Subrecipient Monitoring Eligibility

Other Findings in this Audit

  • 1161189 2022-010
    Material Weakness Repeat
  • 1161190 2022-010
    Material Weakness Repeat
  • 1161191 2022-011
    Material Weakness Repeat
  • 1161193 2022-013
    Material Weakness Repeat
  • 1161194 2022-014
    Material Weakness Repeat
  • 1161195 2022-015
    Material Weakness Repeat
  • 1161196 2022-016
    Material Weakness Repeat
  • 1161197 2022-017
    Material Weakness Repeat
  • 1161198 2022-018
    Material Weakness Repeat
  • 1161199 2022-019
    Material Weakness Repeat
  • 1161200 2022-013
    Material Weakness Repeat
  • 1161201 2022-014
    Material Weakness Repeat
  • 1161202 2022-015
    Material Weakness Repeat
  • 1161203 2022-016
    Material Weakness Repeat
  • 1161204 2022-017
    Material Weakness Repeat
  • 1161205 2022-018
    Material Weakness Repeat
  • 1161206 2022-019
    Material Weakness Repeat
  • 1161207 2022-013
    Material Weakness Repeat
  • 1161208 2022-014
    Material Weakness Repeat
  • 1161209 2022-015
    Material Weakness Repeat
  • 1161210 2022-016
    Material Weakness Repeat
  • 1161211 2022-017
    Material Weakness Repeat
  • 1161212 2022-018
    Material Weakness Repeat
  • 1161213 2022-019
    Material Weakness Repeat
  • 1161214 2022-013
    Material Weakness Repeat
  • 1161215 2022-014
    Material Weakness Repeat
  • 1161216 2022-015
    Material Weakness Repeat
  • 1161217 2022-016
    Material Weakness Repeat
  • 1161218 2022-017
    Material Weakness Repeat
  • 1161219 2022-018
    Material Weakness Repeat
  • 1161220 2022-019
    Material Weakness Repeat
  • 1161221 2022-020
    Material Weakness Repeat
  • 1161222 2022-021
    Material Weakness Repeat
  • 1161223 2022-022
    Material Weakness Repeat
  • 1161224 2022-023
    Material Weakness Repeat
  • 1161225 2022-024
    Material Weakness Repeat
  • 1161226 2022-025
    Material Weakness Repeat
  • 1161227 2022-026
    Material Weakness Repeat
  • 1161228 2022-027
    Material Weakness Repeat
  • 1161229 2022-028
    Material Weakness Repeat
  • 1161230 2022-029
    Material Weakness Repeat
  • 1161231 2022-030
    Material Weakness Repeat
  • 1161232 2022-031
    Material Weakness Repeat
  • 1161233 2022-032
    Material Weakness Repeat
  • 1161234 2022-033
    Material Weakness Repeat
  • 1161235 2022-032
    Material Weakness Repeat
  • 1161236 2022-033
    Material Weakness Repeat
  • 1161237 2022-032
    Material Weakness Repeat
  • 1161238 2022-033
    Material Weakness Repeat
  • 1161239 2022-032
    Material Weakness Repeat
  • 1161240 2022-033
    Material Weakness Repeat
  • 1161241 2022-034
    Material Weakness Repeat
  • 1161242 2022-035
    Material Weakness Repeat
  • 1161243 2022-036
    Material Weakness Repeat
  • 1161244 2022-037
    Material Weakness Repeat
  • 1161245 2022-038
    Material Weakness Repeat
  • 1161246 2022-039
    Material Weakness Repeat
  • 1161247 2022-040
    Material Weakness Repeat
  • 1161248 2022-041
    Material Weakness Repeat
  • 1161249 2022-038
    Material Weakness Repeat
  • 1161250 2022-039
    Material Weakness Repeat
  • 1161251 2022-040
    Material Weakness Repeat
  • 1161252 2022-041
    Material Weakness Repeat
  • 1161253 2022-042
    Material Weakness Repeat
  • 1161254 2022-043
    Material Weakness Repeat
  • 1161255 2022-044
    Material Weakness Repeat
  • 1161256 2022-042
    Material Weakness Repeat
  • 1161257 2022-043
    Material Weakness Repeat
  • 1161258 2022-044
    Material Weakness Repeat
  • 1161259 2022-045
    Material Weakness Repeat
  • 1161260 2022-046
    Material Weakness Repeat
  • 1161261 2022-047
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $243.39M
17.225 UNEMPLOYMENT INSURANCE $49.29M
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $16.73M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $11.02M
10.542 PANDEMIC EBT FOOD BENEFITS $10.37M
97.030 COMMUNITY DISASTER LOANS $8.04M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $7.82M
10.539 CNMI NUTRITION ASSISTANCE $7.49M
97.039 HAZARD MITIGATION GRANT $4.56M
21.026 HOMEOWNER ASSISTANCE FUND $4.16M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $2.73M
66.801 HAZARDOUS WASTE MANAGEMENT STATE PROGRAM SUPPORT $2.51M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2.44M
66.600 ENVIRONMENTAL PROTECTION CONSOLIDATED GRANTS FOR THE INSULAR AREAS - PROGRAM SUPPORT $2.34M
12.617 ECONOMIC ADJUSTMENT ASSISTANCE FOR STATE GOVERNMENTS $1.85M
20.526 BUSES AND BUS FACILITIES FORMULA, COMPETITIVE, AND LOW OR NO EMISSIONS PROGRAMS $1.74M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $1.39M
15.605 SPORT FISH RESTORATION $1.32M
15.611 WILDLIFE RESTORATION AND BASIC HUNTER EDUCATION AND SAFETY $1.28M
93.489 CHILD CARE DISASTER RELIEF $1.24M
20.509 FORMULA GRANTS FOR RURAL AREAS AND TRIBAL TRANSIT PROGRAM $1.19M
11.419 COASTAL ZONE MANAGEMENT ADMINISTRATION AWARDS $954,712
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $830,622
97.067 HOMELAND SECURITY GRANT PROGRAM $781,287
97.U01 FEMA-JFO/DRC-Guard Services $661,485
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $644,809
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $625,444
97.012 BOATING SAFETY FINANCIAL ASSISTANCE $600,225
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $582,229
93.569 COMMUNITY SERVICES BLOCK GRANT $555,046
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $481,476
15.615 COOPERATIVE ENDANGERED SPECIES CONSERVATION FUND $474,763
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $452,548
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $444,555
16.034 CORONAVIRUS EMERGENCY SUPPLEMENTAL FUNDING PROGRAM $442,103
16.575 CRIME VICTIM ASSISTANCE $417,507
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $409,547
11.482 CORAL REEF CONSERVATION PROGRAM $404,632
17.258 WIOA ADULT PROGRAM $382,903
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $368,487
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $360,286
15.634 STATE WILDLIFE GRANTS $333,981
17.259 WIOA YOUTH ACTIVITIES $333,058
93.778 MEDICAL ASSISTANCE PROGRAM $318,867
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $287,347
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $282,833
81.041 STATE ENERGY PROGRAM $281,655
81.042 WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS $278,491
10.649 PANDEMIC EBT ADMINISTRATIVE COSTS $258,116
20.218 MOTOR CARRIER SAFETY ASSISTANCE $246,279
12.600 COMMUNITY INVESTMENT $242,221
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $238,819
17.504 CONSULTATION AGREEMENTS $234,374
97.062 SCIENTIFIC LEADERSHIP AWARDS $216,694
17.235 SENIOR COMMUNITY SERVICE EMPLOYMENT PROGRAM $207,151
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $185,830
64.203 VETERANS CEMETERY GRANTS PROGRAM $175,658
15.663 NFWF-USFWS CONSERVATION PARTNERSHIP $160,217
12.022 DOD MENTOR-PROTEGE PROGRAM $160,121
45.310 GRANTS TO STATES $156,947
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $148,552
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $143,315
16.750 SUPPORT FOR ADAM WALSH ACT IMPLEMENTATION GRANT PROGRAM $135,657
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $135,591
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $118,439
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $112,435
11.472 UNALLIED SCIENCE PROGRAM $112,262
93.464 ACL ASSISTIVE TECHNOLOGY $111,566
17.285 REGISTERED APPRENTICESHIP $104,348
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $103,317
59.061 STATE TRADE EXPANSION $99,650
10.170 SPECIALTY CROP BLOCK GRANT PROGRAM - FARM BILL $98,021
11.437 PACIFIC FISHERIES DATA PROGRAM $93,960
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $83,128
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $79,513
10.664 COOPERATIVE FORESTRY ASSISTANCE $78,427
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $73,223
97.U03 FEMA-IGSA Enhdisasterlegalserv $70,131
11.467 METEOROLOGIC AND HYDROLOGIC MODERNIZATION DEVELOPMENT $64,229
93.048 SPECIAL PROGRAMS FOR THE AGING, TITLE IV, AND TITLE II, DISCRETIONARY PROJECTS $62,557
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $59,975
16.017 SEXUAL ASSAULT SERVICES FORMULA PROGRAM $59,393
10.680 FOREST HEALTH PROTECTION $56,252
97.050 PRESIDENTIAL DECLARED DISASTER ASSISTANCE TO INDIVIDUALS AND HOUSEHOLDS - OTHER NEEDS $44,486
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $42,583
97.008 NON-PROFIT SECURITY PROGRAM $40,698
93.499 LOW INCOME HOUSEHOLD WATER ASSISTANCE PROGRAM $40,185
10.179 MICRO-GRANTS FOR FOOD SECURITY PROGRAM $39,793
93.667 SOCIAL SERVICES BLOCK GRANT $38,860
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $37,209
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $36,068
97.U02 FEMA Cost Share For Tinian $34,834
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $31,544
90.404 HAVA ELECTION SECURITY GRANTS $30,376
17.273 TEMPORARY LABOR CERTIFICATION FOR FOREIGN WORKERS $29,237
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $27,077
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $21,582
93.369 ACL INDEPENDENT LIVING STATE GRANTS $21,096
45.129 PROMOTION OF THE HUMANITIES FEDERAL/STATE PARTNERSHIP $19,840
93.643 CHILDREN'S JUSTICE GRANTS TO STATES $18,435
84.177 REHABILITATION SERVICES INDEPENDENT LIVING SERVICES FOR OLDER INDIVIDUALS WHO ARE BLIND $18,377
66.040 DIESEL EMISSIONS REDUCTION ACT (DERA) STATE GRANTS $17,137
12.113 STATE MEMORANDUM OF AGREEMENT PROGRAM FOR THE REIMBURSEMENT OF TECHNICAL SERVICES $16,417
20.100 AVIATION EDUCATION $14,689
93.669 CHILD ABUSE AND NEGLECT STATE GRANTS $14,311
93.450 EBOLA HEALTHCARE PREPAREDNESS AND RESPONSE FOR SELECT CITIES WITH ENHANCED AIRPORT ENTRANCE SCREENINGS FROM AFFECTED COUNTRIES IN WEST AFRICA $13,717
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $13,076
20.205 HIGHWAY PLANNING AND CONSTRUCTION $12,910
93.630 DEVELOPMENTAL DISABILITIES BASIC SUPPORT AND ADVOCACY GRANTS $11,986
10.U01 DLNR CNMI Fisheries Training $8,033
93.042 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 2, LONG TERM CARE OMBUDSMAN SERVICES FOR OLDER INDIVIDUALS $7,552
19.976 International Narcotics Control and Law Enforcement $6,973
21.019 CORONAVIRUS RELIEF FUND $5,204
11.454 UNALLIED MANAGEMENT PROJECTS $4,630
11.407 INTERJURISDICTIONAL FISHERIES ACT OF 1986 $4,260
11.016 STATISTICAL, RESEARCH, AND METHODOLOGY ASSISTANCE $3,469
15.657 ENDANGERED SPECIES RECOVERY IMPLEMENTATION $2,790
15.631 PARTNERS FOR FISH AND WILDLIFE $2,755
17.600 MINE HEALTH AND SAFETY GRANTS $2,465
66.442 WATER INFRASTRUCTURE IMPROVEMENTS FOR THE NATION SMALL AND UNDERSERVED COMMUNITIES EMERGING CONTAMINANTS GRANT PROGRAM $852
20.514 PUBLIC TRANSPORTATION RESEARCH, TECHNICAL ASSISTANCE, AND TRAINING $794
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $70