Finding Text
2025-002 Eligibility — Temporary Assistance for Needy Families and Emergency Solutions Grants Program Federal agency: U.S. Department of Health and Human Services (TANF); U.S. Department of Housing and Urban Development (ESG). Assistance Listings: 93.558 and 14.231. Federal award numbers were not available; pass-through entity identifying numbers: TANF (Adams County); DOLA DOH ESG, DOLA DOH HSP, DOLA DOH NS2G, DOLA DOH HRP, and DOLA DOH HPAP (State of Colorado); Encampment Resolution (Adams County). Award year: July 1, 2024 through June 30, 2025. Pass-through entities: Adams County (TANF and ESG); State of Colorado, Department of Local Affairs, Division of Housing (ESG). Federal expenditures: $1,079,200 (TANF) and $984,865 (ESG). Compliance requirement: Eligibility. Type of finding: material weakness in internal control over compliance. Repeat finding: Yes - prior-year finding 2024-02. Condition: During our audit of the Temporary Assistance for Needy Families (TANF) program (Assistance Listing 93.558) and the Emergency Solutions Grants Program (Assistance Listing 14.231) for the year ended June 30, 2025, it was noted that the Organization did not maintain adequate supporting documentation for determining client eligibility. Specifically, of the 40 selections tested, the Organization was unable to provide documentation supporting income determination for 1 selection, and documentation supporting United States citizenship or qualified alien status was missing for two selections. Our sample was not intended to be, and was not, a statistically valid sample. Criteria: In accordance with TANF program requirements and 2 CFR § 200.303 (internal controls), recipients must maintain sufficient records to support eligibility determinations. Adequate supporting documentation is essential to ensure compliance with federal guidelines and to prevent improper payments. Cause: The Organization administers the Family Shelter program, which serves individuals who are often unable to provide conventional source documentation supporting income or citizenship status because they are homeless or otherwise without typical identifying records. In those circumstances, the Organization's practice is to obtain a signed statement from the applicant attesting to homelessness, lack of income, or other eligibility criteria in lieu of source documentation. The Organization has a formalized practice through the required client file checklist and written policy requiring case managers to retain either source documentation or a signed self-attestation for each eligibility attribute in the individual client file. The policy was not adhered to by an employee and was not discovered by the quality/compliance control. As a result, for the items tested, neither source documentation nor a signed attestation was retained. Effect: The Organization is unable to demonstrate, through documentation retained in the individual client file, that each eligibility determination was supported by either source documentation or a signed self-attestation. The absence of retained eligibility documentation means that the Organization's internal control cannot be relied upon to ensure that benefits are provided only to eligible TANF program participants and hinders the Organization's ability to demonstrate compliance during federal or pass-through entity monitoring reviews, increasing the risk that material noncompliance with the eligibility compliance requirement could occur without timely detection. Questioned Costs None. No questioned costs are reported because the condition relates to the retention of eligibility documentation rather than to payments to known ineligible participants. Eligibility determinations were performed at intake and signed self-attestation forms were obtained in accordance with the Organization's practice; however, the completed forms were not retained in the individual client files. The audit did not identify any payments to participants determined to be ineligible. Recommendation We recommend the Organization (a) develop and implement a written policy and procedure requiring case managers, at the time of intake, to obtain and retain in the individual client file documentation supporting each TANF eligibility attribute - including income determination and U.S. citizenship or qualified alien status; the policy should expressly permit a signed self-attestation from the client to serve as the supporting documentation when, due to homelessness or other circumstances, conventional source documentation cannot reasonably be obtained; (b) provide periodic training to intake staff on the documentation requirements and acceptable forms of evidence; and (c) implement periodic supervisory review of completed intake files to confirm compliance with the documented retention policy. Management’s Response See corrective action plan.