Finding 1203110 (2025-007)

Material Weakness Repeat Finding
Requirement
ABE
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396345
Organization: Department of Human Services (HI)
Auditor: ACCUITY LLP

AI Summary

  • Core Issue: 13 out of 60 case files lacked necessary documentation, leading to noncompliance with federal requirements.
  • Impacted Requirements: Missing agreements, criminal background checks, difficulty of care determinations, and documentation for subsidy payments after age 18.
  • Recommended Follow-Up: Ensure program staff are trained on all grant requirements and strictly adhere to established policies and procedures.

Finding Text

Condition We selected a non-statistical sample of 60 case files which approximates $29,160 in monthly benefit payments, out of a population of approximately 1,400 case files which approximate $22.2 million in total annual benefit payments, for testing and noted exceptions in 13 case files as follows: • Ten case files where the modified or initial adoption agreement was missing and therefore did not have any support for the amount of monthly assistance paid. • One case file where the State, Federal Bureau of Investigation, and/or child abuse and neglect clearances were missing. • Five case files where the “difficulty of care” determination was missing and therefore did not have any support for the assistance amount paid. • Two case files where the documentation regarding the continuation of the monthly subsidy payments after the child’s 18th birthday was missing. A similar finding was reported in the prior year as Finding No. 2024-006. Criteria Pursuant to 42 USC 673(a)(3), the amount of the adoption assistance payments to be made shall be determined through agreement between the adoptive parents and the State or local agency administering the program, which shall take into consideration the circumstances of the adopting parents and the needs of the child being adopted, and may be readjusted periodically, with the concurrence of the adopting parents (which may be specified in the adoption assistance agreement), depending upon changes in such circumstances. Pursuant to 42 USC 671(a)(20)(A), the State must have procedures for criminal records checks, including a fingerprint-based check of national crime information databases (as defined in 28 USC 534(f)(3)(A)), for any prospective adoptive parent before the adoptive parent may be finally approved for placement of a child. Pursuant to 42 USC 673(c)(1)(B), a difficulty of care determination is required to be completed in order to verify that the child qualifies as having special needs. Pursuant to 42 USC 673(a)(4)(A), assistance payments must stop for a child who has attained 18 years of age or greater or 21 years of age if the State determines that the child has a mental or physical handicap. Effect Failure to follow the established policies and procedures in place over the application process and determination of assistance amount represents an instance of noncompliance with the requirements of 2 CFR Part 200, resulting in questioned costs. Cause and View of Responsible Officials Although the Department has established policies and procedures in place regarding the application process and determination of assistance amount, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including those specified under Criteria above. Additionally, we recommend that the Department diligently comply with its policies and procedures.

Corrective Action Plan

Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Although there was better communication with the auditors this year, Child Welfare Services (CWS) will continue to communicate and share information with auditors to improve understanding during the Title IV-E reviews. Moving forward, it would be beneficial for CWS to hold entrance and exit interviews. The entrance interview would be sharing the tool with the auditors, and the exit interview would be explaining major audit findings and discussion to the final report. Corrective Action Taken or Planned: 1. CWS staff will be informed of the audit findings and corrective action plan, emphasizing the importance of: A. Reviewing their work to ensure diligent compliance with policies and procedures. B. Supervisor coaching, support and review of records/documents for completeness. C. The impact of individual unit records maintenance performance on the outcome of the audit and this corrective action plan. 2. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. Staff will: A. Continue to ensure staff is securing the Adoption Assistance and Legal Guardian permanency assistance forms that provide notice for age changes and payment increases. B. Document the qualifying need for Difficulty of Care (DOC) determination for the records, showing how DOC was calculated and ensuring filed in eligibility record. C. Locate or reprint and file missing “Certificate of Approvals.” D. Locate missing clearances in records not provided for review or re-run them if not located in records reviewed. Please note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. E. For young person(s) in Imua Kakou (IK) who turned 18 while in care, i. CWS will secure a letter for the record, from the school that the young person is attending, which notes when the young person is expected to graduate. ii. Work with IK providers and IK liaison to make sure logs and meeting minutes are in SHAKA. iii. Document (reason for) continuation of monthly subsidy payments after youth turned 18. 3. CWS has identified the Eligibility Unit (FPPEU) record as the primary record for audits with the Licensing record and other case files as secondary. 4. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. A. The FPPEU Administrator and supervisors will review the eligibility unit record checklist and ensure use of checklist will lead to a complete record containing all required documentation. B. FPPEU staff will review error records identified in this audit by following checklists and securing missing documentation, updating inaccurate information and verifying that all necessary documentation is present. i. Staff will be given coaching/supervisory support to correctly complete documentation. ii. Document the qualifying need for Difficulty of Care (DOC) determination for the records, showing how DOC was calculated. iii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. C. The Licensing Unit Section Administrator and supervisors will review error records identified in this audit, secure missing documentation, update inaccurate information and verify that all necessary documentation is present. i. Strategies will be developed with Supervisors to support coaching/supervision to ensure appropriate documentation is reviewed to catch and correct errors. ii. Case specific audit findings and corrective actions taken will be noted in each record where there was a finding. 5. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (MICU) within 90 days to ensure missing documentation has been secured and/or properly noted in record. A. MICU staff will audit records to verify that corrective actions have been completed for case specific audit findings. This includes verifying that records contain a note explaining updated information or information gathered due to audit. B. MICU will work with Branch Administrators, Section Administrators, Social Services Assistants (SSA) and program personnel to ensure file updates with completion of missing information. C. MICU will verify accuracy of DOC calculations for case specific errors noted in this audit, while supervisors will verify accuracy of DOC calculations on an ongoing basis. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1-5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Completion Date: May 31, 2026 Responding Official(s): Kisha C. Raby, Social Services Division Program Development Administrator; Tonia Mahi, Social Services Division Assistant Child Welfare Services Branch Administrator; Lavina Forvilly, Social Services Division Assistant Program Administrator; and Corey Pablo, Social Services Division Management Information Compliance Unit Supervisor

Categories

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Other Findings in this Audit

  • 1203108 2025-009
    Material Weakness Repeat
  • 1203109 2025-010
    Material Weakness Repeat
  • 1203111 2025-008
    Material Weakness Repeat
  • 1203112 2025-011
    Material Weakness Repeat
  • 1203113 2025-012
    Material Weakness Repeat
  • 1203114 2025-013
    Material Weakness Repeat
  • 1203115 2025-006
    Material Weakness Repeat
  • 1203116 2025-006
    Material Weakness Repeat
  • 1203117 2025-014
    Material Weakness Repeat
  • 1203118 2025-014
    Material Weakness Repeat
  • 1203119 2025-014
    Material Weakness Repeat
  • 1203120 2025-003
    Material Weakness Repeat
  • 1203121 2025-004
    Material Weakness Repeat
  • 1203122 2025-005
    Material Weakness Repeat
  • 1203123 2025-003
    Material Weakness Repeat
  • 1203124 2025-004
    Material Weakness Repeat
  • 1203125 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 MEDICAL ASSISTANCE PROGRAM $2.15B
10.551 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $694.52M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $65.98M
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $59.50M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $36.81M
10.646 SUMMER ELECTRONIC BENEFIT TRANSFER PROGRAM FOR CHILDREN $32.44M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $24.00M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $21.36M
93.658 FOSTER CARE TITLE IV-E $19.10M
93.667 SOCIAL SERVICES BLOCK GRANT $16.55M
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $15.12M
93.659 ADOPTION ASSISTANCE $14.73M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $14.33M
96.001 SOCIAL SECURITY DISABILITY INSURANCE $7.86M
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $7.75M
97.088 DISASTER ASSISTANCE PROJECTS $5.87M
93.090 GUARDIANSHIP ASSISTANCE $4.11M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $1.74M
93.777 STATE SURVEY AND CERTIFICATION OF HEALTH CARE PROVIDERS AND SUPPLIERS (TITLE XVIII) MEDICARE $1.30M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $940,051
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $736,396
93.464 ACL ASSISTIVE TECHNOLOGY $683,572
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $594,270
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $571,294
93.669 CHILD ABUSE AND NEGLECT STATE GRANTS $517,826
94.011 AMERICORPS SENIORS FOSTER GRANDPARENT PROGRAM (FGP) 94.011 $416,327
84.177 REHABILITATION SERVICES INDEPENDENT LIVING SERVICES FOR OLDER INDIVIDUALS WHO ARE BLIND $396,635
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $298,741
93.497 FAMILY VIOLENCE PREVENTION AND SERVICES/ SEXUAL ASSAULT/RAPE CRISIS SERVICES AND SUPPORTS $257,427
94.016 AMERICORPS SENIORS SENIOR COMPANION PROGRAM (SCP) 94.016 $216,950
93.603 ADOPTION AND LEGAL GUARDIANSHIP INCENTIVE PAYMENTS PROGRAM $206,000
93.369 ACL INDEPENDENT LIVING STATE GRANTS $185,836
93.643 CHILDREN'S JUSTICE GRANTS TO STATES $151,193
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $136,367
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $104,863
84.187 SUPPORTED EMPLOYMENT SERVICES FOR INDIVIDUALS WITH THE MOST SIGNIFICANT DISABILITIES $104,639
93.599 CHAFEE EDUCATION AND TRAINING VOUCHERS PROGRAM (ETV) $90,544
93.968 STATES ADVANCING ALL-PAYER HEALTH EQUITY APPROACHES AND DEVELOPMENT (AHEAD) MODEL $57,137
93.791 MONEY FOLLOWS THE PERSON REBALANCING DEMONSTRATION $36,428
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $17,218