Finding Text
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E Assistance Listing Number: 93.658 Pass-Through Agency: City of Philadelphia Department of Human Services Contract Number(s): 21-20075, 23-20289 and 23-20800 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Material Weakness in Internal Control over Eligibility Compliance Criteria: 3 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of eligibility and reporting. Concilio’s Community Umbrella Agency Number 3 should have procedures and controls in place to ensure that all client files contained the required documentation to comply with the eligibility and reporting requirements under Uniform Guidance. Condition and Context: In our eligibility test, we requested a sample of 60 foster care children who were managed by Community Umbrella Agency 3 during the fiscal year ended June 30, 2025. As part of our testing, we reviewed each child’s case file in order to determine whether required documentation was included in the file as per the requirements of both the City of Philadelphia, Department of Human Services and the Commonwealth of Pennsylvania, Department of Human Services. Such forms are essential and help to ensure that participants are eligible for, receiving, and reporting the progress of those services provided. The results from this review indicate that documentation was either missing, appeared to have gaps of time between submissions or were not prepared timely. This included the: (a) 43 CUA Safety Assessments, (b) 38 CUA Safety Plans, (c) 15 CUA PA Model Risk Assessments, (d) 8 CUA Documented Client Visits (Structure Case Notes), (e) 21 FAST Family Advocacy Forms, (f) 21 Life Skills Assessment/ Biopsychosocial Evaluation/ IEP or Ages & Stages Questionnaire (ASQ), (g) 15 School Aged Report Cards, (h) 23 CUA Authorization to Release Information, (i) 12 CUA Immunizations, (j) 22 DHS Court Order Sheets, (k) 11 Child’s Photo, (l) 9 Initial CUA Single Case Plan, (m) 11 6-Month Updates to CUA Single Case Plan, (n) 2 Initial CUA Case Service Conference Summary Report, and (o) 2 Six Month Ongoing CUA Services Conference Summary Report. Furthermore, each child's file needed to contain specific documents from the DHS, which had to be supplied by the department or shown evidence of request by the CUA. Missing documents consisted of: (a) 23 DHS Service Authorization Forms, (b) 25 DHS CUA Provider Referral Forms, and (c) 20 DHS CUA In-Home Services Referral Forms. The total number of exceptions throughout totaled 321. Questioned Costs: No Cause: Based on our observations and discussions with management, Concilio encountered logistical challenges while starting-up and onboarding this new program while needing to scale quickly in order to meet the needs of its program consumers. These challenges attributed to the lack of documentation and file management throughout the fiscal year ended June 30, 2025. Effect: Both the lack of proper documentation and the timeliness of the completion of this documentation could lead to children either receiving inappropriate services or missing the required service described in the child’s individualized service plan. Additionally, this could lead to issues of noncompliance and/or additional unwanted liabilities in the welfare of a child had been comprised. Repeat Finding: This is a repeat finding. Recommendation: We recommend that management continue to develop policies and procedures in order to properly include all pertinent documentation within each client file as required by the City of Philadelphia, Department of Human Services. In addition, we recommend that program leadership and/or the quality control department performs periodic audits of the client files to ensure all required documentation is included. Views of responsible officials and planned corrective actions: Please refer to Concilio’s Corrective Action Plan.