Finding 1221608 (2024-049)

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

AI Summary

  • Core Issue: ADSEF lacks a memorandum of understanding with state agencies for income validation, leading to insufficient verification of participant income.
  • Impacted Requirements: Compliance with the Income Eligibility and Verification System (IEVS) is not met, affecting eligibility determinations for TANF benefits.
  • Recommended Follow-Up: Management should secure the necessary agreements and implement training to standardize income validation processes across regions.

Finding Text

FINDING REFERENCE NUMBER 2024-049 FEDERAL PROGRAMS (ALN – 93.558) TEMPORARY ASSISTANCE FOR NEEDY FAMILIES (TANF) U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES AWARD NUMBERS 2022G996117 (Federal Award Year: 10/1/2021 – 9/30/2022) 2023G996117 (Federal Award Year: 10/1/20212 – 9/30/2023) 2401PRTANF1 (Federal Award Years: 10/1/2023 through 9/30/2026) ADMINISTRATION ADMINISTRATION FOR SOCIOECONOMIC DEVELOPMENT OF THE FAMILY (ADSEF, BY ITS SPANISH ACRONYM) COMPLIANCE REQUIREMENT SPECIAL TESTS & PROVISIONS – INCOME ELIGIBILITY AND VERIFICATION SYSTEM TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE CRITERIA Each state shall participate in the Income Eligibility and Verification System (IEVS) required by Section 1137 of the Social Security Act as amended. Under the State Plan the state is required to coordinate data exchanges with other federally assisted benefit programs, request and use income and benefit information when making eligibility determinations and adhere to standardized formats and procedures in exchanging information with other programs and agencies. Specifically, the state is required to request and obtain information as follows (42 USC 1320b-7; 45 CFR section 205.55): a. Wage information from the state Wage Information Collection Agency (SWICA) should be obtained for all applicants at the first opportunity following receipt of the application, and for all recipients on a quarterly basis. b. Unemployment Compensation (UC) information should be obtained for all applicants at the first opportunity, and in each of the first three months in which the individual receives aid. This information should also be obtained in each of the first three months following any recipient-reported loss of employment. If an individual is found to be receiving UC, the information should be requested until benefits are exhausted. c. All available information from the Social Security Administration (SSA) for all applicants at the first opportunity. In addition, in accordance with the State Plan, other internal controls applied by TANF staff to identify employment status and earnings of individuals are the: State Wage Information Collection Agency (SWICA) and the Beneficiary and Earnings Data Exchange (BENDEX). Through our Office of Information System, TANF caseload is cross checked with their database to identify participants that may be working. These systems create a list of participants which is reviewed by the eligibility determination technician. STATEMENT OF CONDITION During our process of understanding internal controls regarding compliance with this requirement, in the interviews conducted with the regions they indicated that they received the SWICA and BENDEX lists monthly. However, ADSEF headquarters indicated that they did not have a memorandum of understanding with the relevant state agencies for the 2023-2024 fiscal year. In all regions, we were told that the income reported by participants was validated only with a sworn statement. QUESTIONED COSTS None. PERSPECTIVE INFORMATION This is a systematic deficiency. According to interviews conducted with technicians in different regions, we identified a lack of uniformity in the income validation processes and a lack of awareness of what the current regulations establish. STATEMENT OF CAUSE ADSEF does not have a memorandum of understanding that allows access to participants' income validation. Additionally, they do not have agreements with the relevant agencies to verify this requirement. POSSIBLE ASSERTED EFFECT ADSEF does not have sufficient mechanisms to validate the entry of participants requesting the benefit and does not allow compliance with this requirement. IDENTIFICATION OF REPEAT FINDING This is a repeat of a finding reported in the prior audit as Finding Numbers is 2023-027/2023-058. RECOMMENDATIONS We recommend that management coordinate the signing of the memorandum of understanding with the relevant agencies. Additionally, establish processes and training aligned with the procedures and documentation currently in use.

Corrective Action Plan

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a verification framework. We are prioritizing the formalization of inter-agency data sharing agreements, the implementation of standardized income validation protocols, and the execution of a comprehensive training program to ensure all regional staff adhere to federal IEVS requirements. Action Steps: 1. MOU Formalization – Execute and maintain active Memoranda of Understanding (MOUs) with all relevant agencies to secure legal access to real-time wage, unemployment, and benefit data. 2. Develop and mandate a new "Income Eligibility Validation SOP". This protocol will strictly forbid reliance on sworn statements alone and will require technicians to cross-reference application data against verified external agency sources. 3. Integrated Data Exchange Protocol – Implement a recurring, automated schedule for the ingestion of SWICA, UC, and BENDEX/SSA data into our internal eligibility systems, ensuring data is available to technicians at the point of application and during quarterly reviews. 4. Implement a Training Curriculum – Launch a recurring, mandatory training program for all regional eligibility technicians and supervisors, focusing on federal IEVS requirements, standardized data validation procedures, and the legal consequences of non-compliance. 5. Implement a monthly "Eligibility Quality Assurance" review, where central-level management audits a sample of case files to ensure that income has been verified against external sources as required by the State Plan. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Gerhil Medina Baez Auxiliary Administrator Operational Services

Categories

Special Tests & Provisions Eligibility Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

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
  • 1221558 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
  • 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