Finding 1190743 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 394974
Organization: County of Loudoun, Virginia (VA)

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, specifically regarding timely eligibility redeterminations for Medicaid beneficiaries.
  • Impacted Requirements: The County failed to perform required eligibility renewals within the mandated twelve-month period, violating federal and state compliance standards.
  • Recommended Follow-Up: The County should strengthen internal controls for eligibility reviews and increase random checks to ensure compliance with renewal timelines and documentation requirements.

Finding Text

Finding 2025-001: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Health and Human Services (HHS) State Awarding Agency: Virginia Department of Social Services (VDSS) Program Name: Medicaid Cluster ALN: 93.778 Compliance Requirement: Eligibility Prior Year Audit Finding Number: 2024-002 Criteria: Per Title 2 Subpart §200.303, “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.” Per Subchapter M1520.001 of the Virginia Medical Assistance Eligibility Manual, “An annual review of all of the enrollee's eligibility requirements is called a ‘redetermination’ or ‘renewal’.” A renewal of the enrollee's eligibility must be completed at least once every twelve (12) months. Condition: During our testing of sixty (60) beneficiaries that were enrolled in the Medical Assistance Program, we noted sixteen (16) beneficiaries continued to receive medical assistance when an eligibility redetermination was not performed within twelve (12) months of the prior eligibility determination. For all sixteen (16) of these instances, the redeterminations were performed late with beneficiaries found to have been eligible. Additionally, we noted one (1) instance in which a beneficiary did not provide required verification documentation by the required due date, however, temporary benefits were not terminated timely. Cause: The County does not appear to have adequate policies and procedures in place to ensure a consistent and systematic review of the beneficiary case files. Effect: The Medical Assistance Program as operated by the County was not in compliance with the eligibility compliance requirement as of June 30, 2025. Additionally, failure to timely perform renewals could result in medical assistance rendered to ineligible individuals. Medical assistance payments to individuals are paid directly by the state. Recommendation: The County should implement a plan to enhance internal controls related to participant eligibility to ensure renewals are occurring on a timely basis and files contain adequate supporting documentation in accordance with the Uniform Guidance. The County should also consider increasing the number of haphazard reviews of eligibility determinations performed throughout the year. Questioned costs: Not determinable. Context: This is a condition based on testing of the County’s compliance with specified requirements. The prevalence of the finding is detailed in the condition section above. The samples were selected using a nonstatistical method. Views of Responsible Officials: The County concurs with the auditor’s finding and recommendation.

Corrective Action Plan

Finding 2025-001: Material Weakness in Internal Control Over Compliance and Non-Material Noncompliance Federal Awarding Agency: Department of Health and Human Services (HHS) Responsible Person: Deidra Bolden, Acting Director, Department of Family Services Estimated Completion: June 30, 2026 Corrected Action: 1. The Department of Family Services has implemented a Medicaid-focused caseworker structure and a specialized intake-and-ongoing case management model. This model reduces task switching and allows staff to develop proficiency more quickly by focusing on Medicaid and progressing from simpler to more complex case types. It also improves consistency in case processing and allows supervisors to provide more targeted oversight. The Department has also completed a Medicaid Overdue Resolution Project, significantly reducing backlog and stabilizing renewal processing. These structural changes, combined with reduced caseloads and increased supervisory capacity, allow for more focused case management, improved oversight, and more consistent application of eligibility policy. 2. The Department has expanded training capacity and structure to address prior limitations. A second trainer position has been added, doubling internal training capacity and enabling more frequent onboarding, refresher training, and targeted instruction. This allows the Department to better support both new and tenured staff and respond more quickly to identified training needs. In addition, the Department is implementing a competency-based training model that establishes structured learning pathways for new staff, experienced workers, and supervisors. This model incorporates modular curriculum, scenario-based application, and targeted refreshers tied to error trends, supporting more consistent policy application and stronger staff development over time. 3. The Department is strengthening monitoring and case review practices to improve early detection of issues and reinforce consistent oversight. As supervisory capacity has increased and caseloads have begun to stabilize, supervisors are better positioned to conduct more frequent and targeted case reviews, particularly for high-risk and time-sensitive work. The Department is also strengthening case review capacity and moving toward a higher percentage of routine case review to improve early detection of errors and reinforce policy compliance. Trend analysis is being expanded to identify patterns across workers, supervisors, and case types, allowing for more targeted and timely corrective action. These enhancements, supported by improved staffing levels and more manageable caseloads, strengthen the Department’s ability to identify issues earlier, reinforce expectations consistently, and reduce the likelihood of overdue or noncompliant cases. 4. The Department is strengthening how it evaluates the effectiveness of corrective actions by conducting on going case reviews, monthly performance monitoring to track timeliness and accuracy trends, performing trend analysis over time to measure improvement and identify recurring issues, and conducting executive-level reporting to monitor progress and ensure accountability. These evaluation methods provide a structured approach to verifying that corrective actions are implemented effectively and produce sustained improvement. 5. The Department has onboarded additional staff, including supervisors, case managers, a case reviewer, and a trainer, improving both workload distribution and monitoring capacity. Continued investment in staffing, combined with ongoing efforts to right-size caseloads, is expected to further strengthen supervisory oversight, expand case review capacity, and sustain improvements in timeliness and compliance.

Categories

Eligibility HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1190744 2025-002
    Material Weakness Repeat
  • 1190745 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 SPECIAL EDUCATION GRANTS TO STATES $15.13M
14.871 SECTION 8 HOUSING CHOICE VOUCHERS $13.20M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $5.17M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $4.31M
93.778 MEDICAL ASSISTANCE PROGRAM $4.27M
10.553 SCHOOL BREAKFAST PROGRAM $3.41M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.51M
14.251 ECONOMIC DEVELOPMENT INITIATIVE, COMMUNITY PROJECT FUNDING, AND MISCELLANEOUS GRANTS $2.26M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $1.47M
93.658 FOSTER CARE TITLE IV-E $1.40M
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $1.35M
14.879 MAINSTREAM VOUCHERS $1.33M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $1.27M
93.600 HEAD START $1.16M
93.667 SOCIAL SERVICES BLOCK GRANT $1.04M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $1.03M
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $967,583
84.425 EDUCATION STABILIZATION FUND $899,787
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $841,548
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $839,013
93.659 ADOPTION ASSISTANCE $719,660
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $718,020
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $657,186
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $591,721
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $416,506
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $352,093
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $339,694
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $328,320
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $306,030
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $303,973
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $294,963
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $224,852
16.922 EQUITABLE SHARING PROGRAM $213,915
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $181,088
81.128 ENERGY EFFICIENCY AND CONSERVATION BLOCK GRANT PROGRAM (EECBG) $170,382
97.067 HOMELAND SECURITY GRANT PROGRAM $169,329
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $168,972
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $166,947
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $146,386
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $133,911
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $126,926
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $119,475
93.788 OPIOID STR $118,192
14.896 FAMILY SELF-SUFFICIENCY PROGRAM $104,571
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $97,662
12.999 JROTC $96,371
93.217 FAMILY PLANNING SERVICES $95,403
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $85,841
93.472 TITLE IV-E PREVENTION PROGRAM $82,155
20.939 SAFE STREETS AND ROADS FOR ALL $71,529
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $69,355
10.558 CHILD AND ADULT CARE FOOD PROGRAM $62,250
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $61,399
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $58,372
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $53,620
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $52,012
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $48,690
93.116 PROJECT GRANTS AND COOPERATIVE AGREEMENTS FOR TUBERCULOSIS CONTROL PROGRAMS $48,139
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $43,965
16.839 STOP SCHOOL VIOLENCE $40,418
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $32,488
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $31,383
16.825 SMART PROSECUTION INITIATIVE $28,662
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $24,570
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $23,519
20.607 ALCOHOL OPEN CONTAINER REQUIREMENTS $22,623
10.555 NATIONAL SCHOOL LUNCH PROGRAM $22,414
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $18,383
84.013 TITLE I STATE AGENCY PROGRAM FOR NEGLECTED AND DELINQUENT CHILDREN AND YOUTH $15,460
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $15,000
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $14,393
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $9,725
93.008 MEDICAL RESERVE CORPS SMALL GRANT PROGRAM $5,857
16.590 GRANTS TO ENCOURAGE ARREST POLICIES AND ENFORCEMENT OF PROTECTION ORDERS PROGRAM $5,302
15.226 PAYMENTS IN LIEU OF TAXES $4,291
93.090 GUARDIANSHIP ASSISTANCE $3,763
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $2,000
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $2,000
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $1,303
93.041 SPECIAL PROGRAMS FOR THE AGING, TITLE VII, CHAPTER 3, PROGRAMS FOR PREVENTION OF ELDER ABUSE, NEGLECT, AND EXPLOITATION $1,236