Finding 1215888 (2025-006)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-05-28
Audit: 402459
Auditor: SIKICH CPA LLC

AI Summary

  • Core Issue: Missing or untimely eligibility documentation for nine TANF participants prevents verification of compliance with program requirements.
  • Impacted Requirements: Noncompliance with 2 CFR §200.300(b) and §200.303 regarding eligibility documentation and internal controls.
  • Recommended Follow-Up: Establish formal procedures for timely eligibility determinations and retention of documentation, along with a review process to ensure completeness before benefits are issued.

Finding Text

Condition: During our testing of program eligibility for the TANF program, we tested a nonstatistical sample of 40 participant files. For two participants, eligibility determinations could not be located. Additionally, for seven participants, eligibility determinations provided were either not dated or dated after fiscal year end (December 31, 2025). As a result, we were unable to determine whether eligibility had been properly documented prior to the participant beginning the program, as required. Criteria: Under 2 CFR §200.300(b), non Federal entities must comply with federal statutes, regulations, and the terms and conditions of federal awards. Eligibility is a compliance requirement identified in the Compliance Supplement for the TANF program. Additionally, 2 CFR §200.303 requires non Federal entities to establish and maintain effective internal control over federal awards to provide reasonable assurance that the entity is administering federal awards in compliance with program requirements. Adequate documentation supporting participant eligibility must be retained in accordance with 2 CFR §200.334. Cause: The finding resulted from a lack of formal controls over the review, documentation, and retention of TANF eligibility determinations. Specifically, there were no documented procedures to ensure eligibility determinations were completed, dated timely, and retained prior to participant enrollment. Effect: Because eligibility documentation was missing or not timely for nine participants, we were unable to verify compliance with TANF eligibility requirements. This resulted in questioned costs of $4,474 related to benefits provided to participants whose eligibility could not be substantiated. Questioned Costs: $4,474 Recommendation: We recommend that management establish formal procedures to ensure TANF eligibility determinations are completed, reviewed, and dated prior to participant enrollment and that all supporting documentation is retained in accordance with federal requirements. Additionally, management should consider implementing a documented review process to verify eligibility files are complete before benefits are provided.

Corrective Action Plan

The BGCNEO accounting team and government grants team will develop and maintain a shared drive to securely store all required eligibility forms and supporting documentation. Prior to submitting grant billings, BGCNEO accounting staff will review the shared drive to ensure all billed participants have the appropriate documentation on file and have received approved eligibility determination from the funder.

Categories

Eligibility Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1215882 2025-004
    Material Weakness Repeat
  • 1215883 2025-005
    Material Weakness Repeat
  • 1215884 2025-005
    Material Weakness Repeat
  • 1215885 2025-005
    Material Weakness Repeat
  • 1215886 2025-006
    Material Weakness Repeat
  • 1215887 2025-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $2.15M
10.558 CHILD AND ADULT CARE FOOD PROGRAM $403,513
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $152,130
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $150,000