Finding 1166208 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2025-12-22

AI Summary

  • Core Issue: Emerge failed to maintain proper documentation to confirm TANF eligibility, specifically regarding participants' pregnancy status and dependents.
  • Impacted Requirements: This noncompliance violates eligibility criteria for TANF, which requires proof of financial need and family composition.
  • Recommended Follow-Up: Management should enhance training for intake staff to ensure thorough documentation of eligibility criteria before classifying participants as TANF eligible.

Finding Text

Finding Number: 2025‐001 Repeat Finding: No Program Name/Assistance Listing Title: Temporary Assistance for Needy Families (TANF) Assistance Listing Number: 93.558 Federal Agency: U.S. Department of Health and Human Services Federal Award Number: CTR066206, CTR064289 Pass‐Through Agency: Arizona Department of Economic Security, Arizona Foundation for Legal Services Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Eligibility Criteria Under eligibility guidelines for the Temporary Assistance for Needy Families (TANF) program, only financially needy families that consist of a minor child living with a parent or a pregnant woman may receive TANF assistance. In accordance with 2 CFR 200.303, management is responsible for establishing and maintaining internal controls over federal programs, which includes developing a system to ensure documentation is maintained to support that program participants meet the TANF eligibility requirements. Condition The documentation Emerge maintained for participants reported as TANF eligible did not always include information on whether the participant was pregnant or had children or dependents under the age of 19. Cause Emerge’s internal controls over documenting client information in the client management software were not adequate. Effect Two participants were incorrectly designated as TANF eligible. Context During our review of files for TANF eligible participants, we noted that for two of 21 participants reviewed, Emerge did not maintain documentation that indicated whether the participant was pregnant or had children or dependents under the age of 19. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Management should ensure that intake staff not only inquire whether participants meet TANF eligibility requirements, but also document such information prior to classifying the individual as TANF eligible. Views of Responsible Officials See Corrective Action Plan.

Corrective Action Plan

Finding Number: 2025‐001 Program Name/Assistance Listing Title: Temporary Assistance for Needy Families (TANF) Assistance Listing Number: 93.558 Contact Person: Elise Lopez – Vice President, Organizational Operations Anticipated Completion Date: January 31, 2026 Planned Corrective Action: The TANF Cash Assistance eligibility for each client served is one of the dozens of data points that Emerge tracks as part of our requirements for the Arizona Department of Economic Security (ADES) funding. The categorization of whether clients are eligible for TANF Cash Assistance, while a reporting requirement, is not tied to our contract billing. In other words, the accuracy of this categorization does not affect Emerge’s funding in any manner, and reporting errors regarding this categorization has not – and cannot – result in over‐billing for service units within the contract. Nevertheless, Emerge takes its reporting obligations very seriously and strives to always provide the most complete and accurate data to funders and the community. In regard to determining a client’s eligibility for TANF Cash Assistance or other government benefits, Emerge collects information and assesses eligibility for two reasons: 1) as a means of supporting our case management services and efforts to connect clients with appropriate resources, and 2) in order to comply with ADES requests to report whether or not we serve TANF‐eligible clients. While Emerge and its employees are not trained by ADES in determining individual’s eligibility for TANF Cash Assistance or other government benefits that we do not administer, we do provide our own internal training to employees about the factors that go into determining eligibility. Historically, this information has been provided as a stand‐alone document and noted during new hire training. In researching the client files which were selected for audit, it was determined that, in some instances, clients were categorized incorrectly, or that qualifying information was not sufficiently documented as it pertains to the client’s TANF Cash Assistance eligibility. Overwhelmingly, this was a result of one or both of the following factors: (1) clients whose TANF eligibility changed during the year, but whose status was not updated in our system, and/or (2) inconsistencies in how a client’s children had been documented in our client information system (eg. clients whose children are not enrolled in Emerge’s services do not appear in this system, but staff may have marked the client eligible for TANF based on verbal information without documenting the children in their notes). Our internal inquiry into this issue also revealed that TANF income eligibility charts were not correctly updated in all areas of the client information system, which may have led to confusion among staff regarding client eligibility status changes throughout the year. To mitigate future errors, we have taken immediate steps to begin the process of updating our client information system to ensure the correct TANF eligibility charts are reflected in the appropriate areas. We also have a plan to update TANF eligibility chart updates annually, which will include a quality assurance check by the Vice President of Operations to ensure the information has been updated in all appropriate areas of the client data managements system. As of November 28, 2025, we have developed an internal performance improvement plan. This plan includes conducting an internal audit of our client information system files for 2025 to ensure accuracy, re‐training staff on TANF eligibility and documentation, and conducting monthly quality assurance checks through the end of FY26. Additionally, greater time and focus related to the details surrounding the TANF assessment process will be built into the curriculum for new hire trainings moving forward. These corrective actions, while ongoing, are expected to be fully implemented by 01.31.2026

Categories

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1166207 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $1.68M
14.267 CONTINUUM OF CARE PROGRAM $261,324
16.021 JUSTICE SYSTEMS RESPONSE TO FAMILIES $213,392
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $186,645
16.888 CONSOLIDATED AND TECHNICAL ASSISTANCE GRANT PROGRAM TO ADDRESS CHILDREN AND YOUTH EXPERIENCING DOMESTIC AND SEXUAL VIOLENCE AND ENGAGE MEN AND BOYS AS ALLIES $169,173
16.736 TRANSITIONAL HOUSING ASSISTANCE FOR VICTIMS OF DOMESTIC VIOLENCE, DATING VIOLENCE, STALKING, OR SEXUAL ASSAULT $135,434
93.667 SOCIAL SERVICES BLOCK GRANT $134,502
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $117,814
16.575 CRIME VICTIM ASSISTANCE $90,930
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $60,543
16.526 OVW TECHNICAL ASSISTANCE INITIATIVE $44,464
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $43,949
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $26,970