Finding 1221558 (2024-030)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2026-06-30

AI Summary

  • Core Issue: There are significant deficiencies in internal controls regarding eligibility determinations for child care services, including missing documentation and signatures.
  • Impacted Requirements: Compliance with 45 CFR sections 98.20(a) for child eligibility, which includes age verification and proper documentation.
  • Recommended Follow-Up: ACUDEN should enhance internal controls to ensure thorough eligibility checks and documentation at all stages of the process.

Finding Text

FINDING REFERENCE NUMBER 2024-030 FEDERAL PROGRAMS (ALN – 93.489; 93.575 AND 93.596) CHILD CARE AND DEVELOPMENT FUND CLUSTER (ALN – 93.489; 93.575 AND 93.596) COVID-19 – CHILD CARE AND DEVELOPMENT FUND CLUSTER U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBERS G2301PRCCDT (Federal Award Years: 10/1/2022 through 9/30/2025) G2001PRCCC3 (Federal Award Years: 10/1/2019 through 9/30/2025), G2001PRCCDX (Federal Award Years: 01/19/2019 through 9/30/2025), G2101PRCCC5 (Federal Award Years: 12/27/2020 through 9/30/2025), G2101PRCDC6 (Federal Award Years: 10/1/2020 through 9/30/2025), G2101PRCSC6 (Federal Award Years: 10/01/2020 through 09/30/2025) ADMINISTRATION ADMINISTRATION FOR THE CARE AND COMPREHENSIVE DEVELOPMENT OF CHILDREN (ACUDEN, BY ITS SPANISH ACRONYM) COMPLIANCE REQUIREMENT ELIGIBILITY TYPE OF FINDING INTERNAL CONTROL – SIGNIFICANT DEFICIENCY CRITERIA According to the 45 CFR sections 98.20(a) state the child’s eligibility requirements for child care services as following: (a) To be eligible for services under § 98.50, a child shall, at the time of eligibility determination or redetermination: (1) Be under 13 years of age; or, (2) At the option of the Lead Agency, be under age 19 and physically or mentally incapable of caring for himself or herself, or under court supervision; (3) Reside with a family whose income does not exceed 85 percent of the State's median income (SMI), which must be based on the most recent SMI data that is published by the Bureau of the Census, for a family of the same size; and (4) Whose family assets do not exceed $1,000,000 (as certified by such family member); and (5) Reside with a parent or parents who are working or attending a job training or educational program; or (6) Receive, or need to receive, protective services, which may include specific populations of vulnerable children as identified by the Lead Agency, and reside with a parent or parents other than the parent(s) described in paragraph (a)(3)(i) of this section. (i) At grantee option, the requirements in paragraph (a)(2) of this section may be waived for families eligible for child care pursuant to this paragraph, if determined to be necessary on a case-by-case basis. (ii) At grantee option, the waiver provisions in paragraph (a)(3)(ii)(A) of this section apply to children in foster care when defined in the Plan, pursuant to § 98.16(g)(7). STATEMENT OF CONDITION For a sample selected of forty (40) items from a population size of 15,466 participants for the performance of the Eligibility Test, we found the following conditions: 1. For one (1) participant the program could not provide the Birth Certificate to support and validate the child age required for eligibility purpose. 2. For one (1) participant we found that the Eligibility Certificate issued by the program was not signed by the Technician or the Coordinator for eligibility reviewing procedures purpose. 3. For twenty-three (23) participants which were beneficiaries of the Child Care through the Cares Act funds, we noted that the Eligibility Certificate issued does not provide to include the Coordinator signature for eligibility reviewing procedures purpose. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This is a systemic deficiency in internal controls. During the participant eligibility determination test, which consisted to verifying the participants compliance with eligibility requirements, and the verification of the eligibility internal control in place for the assurance of the participants eligibility compliance, we noted the deficiencies established in the condition section. The sample was statistically valid. STATEMENT OF CAUSE 1. The program coordinator indicated that due to the data migration from the CIMA system to the ACUDEN Digital platform and the lack filing documentation, the Birth Certificate was missing to be provided. 2. For missing signatures in the Eligibility Certificate, the program indicated that there was no verification procedure performed for this case. 3. For the Coordinator reviewer signature exclusion in the Eligibility Certificate for the Child Care service through the Cares Act funds, the program indicated to us that this occurred due to the rapid spending funds procedure implementation. The program started to spend the funds as soon as possible and this reviewing signature was not incorporated as part of the Eligibility Certificate. POSSIBLE ASSERTED EFFECT The poor internal controls implementation could result in improper eligibility determination, increasing the risk of noncompliance and that may result in an improper use of funds. In addition, potential recipients of CARES Act funds may also be affected. IDENTIFICATION OF REPEAT FINDING This is a repeat of a finding reported in the prior audit as Finding Numbers 2023-009/2023-037. RECOMMENDATIONS We recommend ACUDEN strengthen internal controls to ensure complete and accurate eligibility determination considering all the participant information at all eligibility determination stages of the process.

Corrective Action Plan

VIEWS OF RESPONSIBLE OFFICIALS ACUDEN is committed to reinforcing our eligibility determination process by standardizing review workflows. We are prioritizing the completion of all missing documentation for affected files and ensuring that every future Eligibility Certificate reflects the required technical and supervisory validations to guarantee compliance. The following corrective actions will be implemented: 1. ACUDEN will recruit at least two (2) staff members to support the implementation of the eligibility verification protocol and ensure adequate capacity for document review. 2. A verification protocol will be established to confirm that all required supporting documents are present and complete prior to finalizing eligibility determinations. A standardized checklist will be created to ensure no document is missing, including during data migration processes. 3. ACUDEN will implement a mandatory dual- verification procedure for all Eligibility Certificates, requiring both the Technician and the Coordinator to sign prior to issuance. IMPLEMENTATION DATE September 2026 RESPONSIBLE PERSON Child Care Director – Sidnia Velez Assistant Administrator for Human Resources – Alex Lopez

Categories

Eligibility Significant Deficiency Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1221540 2024-020
    Material Weakness Repeat
  • 1221541 2024-021
    Material Weakness Repeat
  • 1221542 2024-022
    Material Weakness Repeat
  • 1221543 2024-023
    Material Weakness Repeat
  • 1221544 2024-023
    Material Weakness Repeat
  • 1221545 2024-023
    Material Weakness Repeat
  • 1221546 2024-023
    Material Weakness Repeat
  • 1221547 2024-024
    Material Weakness Repeat
  • 1221548 2024-024
    Material Weakness Repeat
  • 1221549 2024-025
    Material Weakness Repeat
  • 1221550 2024-025
    Material Weakness Repeat
  • 1221551 2024-026
    Material Weakness Repeat
  • 1221552 2024-027
    Material Weakness Repeat
  • 1221553 2024-028
    Material Weakness Repeat
  • 1221554 2024-029
    Material Weakness Repeat
  • 1221555 2024-030
    Material Weakness Repeat
  • 1221556 2024-030
    Material Weakness Repeat
  • 1221557 2024-030
    Material Weakness Repeat
  • 1221559 2024-031
    Material Weakness Repeat
  • 1221560 2024-032
    Material Weakness Repeat
  • 1221561 2024-033
    Material Weakness Repeat
  • 1221562 2024-034
    Material Weakness Repeat
  • 1221563 2024-035
    Material Weakness Repeat
  • 1221564 2024-035
    Material Weakness Repeat
  • 1221565 2024-035
    Material Weakness Repeat
  • 1221566 2024-035
    Material Weakness Repeat
  • 1221567 2024-035
    Material Weakness Repeat
  • 1221568 2024-035
    Material Weakness Repeat
  • 1221569 2024-035
    Material Weakness Repeat
  • 1221570 2024-035
    Material Weakness Repeat
  • 1221571 2024-035
    Material Weakness Repeat
  • 1221572 2024-035
    Material Weakness Repeat
  • 1221573 2024-035
    Material Weakness Repeat
  • 1221574 2024-035
    Material Weakness Repeat
  • 1221575 2024-035
    Material Weakness Repeat
  • 1221576 2024-036
    Material Weakness Repeat
  • 1221577 2024-036
    Material Weakness Repeat
  • 1221578 2024-036
    Material Weakness Repeat
  • 1221579 2024-036
    Material Weakness Repeat
  • 1221580 2024-036
    Material Weakness Repeat
  • 1221581 2024-036
    Material Weakness Repeat
  • 1221582 2024-036
    Material Weakness Repeat
  • 1221583 2024-036
    Material Weakness Repeat
  • 1221584 2024-036
    Material Weakness Repeat
  • 1221585 2024-036
    Material Weakness Repeat
  • 1221586 2024-036
    Material Weakness Repeat
  • 1221587 2024-036
    Material Weakness Repeat
  • 1221588 2024-036
    Material Weakness Repeat
  • 1221589 2024-037
    Material Weakness Repeat
  • 1221590 2024-038
    Material Weakness Repeat
  • 1221591 2024-038
    Material Weakness Repeat
  • 1221592 2024-038
    Material Weakness Repeat
  • 1221593 2024-038
    Material Weakness Repeat
  • 1221594 2024-039
    Material Weakness Repeat
  • 1221595 2024-040
    Material Weakness Repeat
  • 1221596 2024-041
    Material Weakness Repeat
  • 1221597 2024-042
    Material Weakness Repeat
  • 1221598 2024-043
    Material Weakness Repeat
  • 1221599 2024-044
    Material Weakness Repeat
  • 1221600 2024-044
    Material Weakness Repeat
  • 1221601 2024-045
    Material Weakness Repeat
  • 1221602 2024-046
    Material Weakness Repeat
  • 1221603 2024-046
    Material Weakness Repeat
  • 1221604 2024-047
    Material Weakness Repeat
  • 1221605 2024-048
    Material Weakness Repeat
  • 1221606 2024-048
    Material Weakness Repeat
  • 1221607 2024-048
    Material Weakness Repeat
  • 1221608 2024-049
    Material Weakness Repeat
  • 1221609 2024-050
    Material Weakness Repeat
  • 1221610 2024-051
    Material Weakness Repeat
  • 1221611 2024-052
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $92.49M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $56.25M
93.658 FOSTER CARE TITLE IV-E $52.54M
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $30.11M
10.542 PANDEMIC EBT FOOD BENEFITS $29.17M
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $28.11M
93.560 PAYMENTS TO TERRITORIES €“ ADULTS $26.26M
93.563 CHILD SUPPORT SERVICES $25.32M
93.667 SOCIAL SERVICES BLOCK GRANT $17.75M
96.001 SOCIAL SECURITY DISABILITY INSURANCE $13.48M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $6.43M
93.659 ADOPTION ASSISTANCE $4.37M
10.568 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMINISTRATIVE COSTS) $4.35M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $3.38M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $3.12M
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $3.02M
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2.87M
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $2.36M
93.356 HEAD START DISASTER RECOVERY $1.81M
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $1.30M
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $1.24M
93.600 HEAD START $941,560
93.590 COMMUNITY-BASED CHILD ABUSE PREVENTION GRANTS $829,081
93.497 FAMILY VIOLENCE PREVENTION AND SERVICES/ SEXUAL ASSAULT/RAPE CRISIS SERVICES AND SUPPORTS $712,602
93.090 GUARDIANSHIP ASSISTANCE $691,532
10.566 NUTRITION ASSISTANCE FOR PUERTO RICO $686,567
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $656,571
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM $628,994
93.669 CHILD ABUSE AND NEGLECT STATE GRANTS $492,642
10.558 CHILD AND ADULT CARE FOOD PROGRAM $467,546
10.649 PANDEMIC EBT ADMINISTRATIVE COSTS $364,443
93.643 CHILDREN'S JUSTICE GRANTS TO STATES $300,072
14.267 CONTINUUM OF CARE PROGRAM $299,310
93.499 LOW INCOME HOUSEHOLD WATER ASSISTANCE PROGRAM $295,355
93.599 CHAFEE EDUCATION AND TRAINING VOUCHERS PROGRAM (ETV) $172,527
93.489 CHILD CARE DISASTER RELIEF $102,530
93.597 GRANTS TO STATES FOR ACCESS AND VISITATION PROGRAMS $18,065