Finding 1221609 (2024-050)

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

AI Summary

  • Core Issue: ADSEF lacks a proper archiving process for participant files, leading to difficulties in identifying and reviewing necessary documentation for compliance.
  • Impacted Requirements: Failure to refer non-cooperative individuals to child support enforcement and inadequate evidence in participant files violates federal compliance standards.
  • Recommended Follow-Up: Management should implement a robust internal control system for archiving files and ensure staff are trained on maintaining required documentation for audits.

Finding Text

FINDING REFERENCE NUMBER 2024-050 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 – CHILD SUPPORT NON-COOPERATION TYPE OF FINDING INTERNAL CONTROL AND COMPLIANCE – MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE CRITERIA In accordance with 45 CFR sections 264.30 and 264.31 establishes that (a): (1) The State agency must refer all appropriate individuals in the family of a child, for whom paternity has not been established or for whom a child support order needs to be established, modified or enforced, to the child support enforcement agency (i.e., the IV- D agency). (2) Referred individuals must cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for a good cause or other exception established by the State agency responsible for making good cause determinations in accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with § 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency must then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family of the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the family any assistance under the program. STATEMENT OF CONDITION As part of our understanding of internal controls and compliance related to this requirement, we requested a list from the Case Management and Information System (SAIC) that would identify participants who did not meet this requirement. From a population of seven participants, two were selected to validate compliance with this requirement. We were not provided with any file. Additionally, according to our eligibility testing, we were unable to identify child support evidence in 14 files (see finding 2024-028). QUESTIONED COSTS None. PERSPECTIVE INFORMATION This deficiency is systematic. ADSEF lacks an adequate process for archiving files and the information each file should contain. This is a statistically valid sample. STATEMENT OF CAUSE ADSEF does not have an adequate archiving process that allows for the identification of files in a reasonable timeframe. Additionally, there is no formal training or archive process for all regions and local authorities for the personnel involved in determining eligibility and the required evidence that should be kept for the audit process. POSSIBLE ASSERTED EFFECT ADSEF was unable to provide the requested information for auditing within a reasonable timeframe. Furthermore, the lack of a uniform archiving process prevents the information contained in the files from being properly identified and reviewed. IDENTIFICATION OF REPEAT FINDING This is a repeat of a finding reported in the prior audit as Finding Number 2023-059. RECOMMENDATIONS We recommend that management establish an adequate internal controls process that provides for the archiving of information in participant files and the identification of files within a reasonable timeframe.

Corrective Action Plan

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing rigorous documentation and archiving framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to ensure that all eligibility and non-cooperation evidence is preserved, organized, and readily accessible for audit and verification purposes. Action Steps: 1. Implement a new "Uniform Record Retention & Archiving SOP" that mandates a specific organization, labeling, and storage legend for all participant files, ensuring uniform accessibility across all regions. 2. Revise the Eligibility Documentation Checklist that must be completed for every participant, specifically requiring proof of child support referrals and, where applicable, non-cooperation determinations. 3. Formalize the communication protocol between the IV-A (ADSEF) and IV-D (Child Support) agencies to ensure prompt notification and documentation of non-cooperation instances, as required by 45 CFR §264.30(b). 4. Conduct a mandatory regional training curriculum for all regional staff on the importance of file maintenance, the specific requirements for child support referrals, and the legal protocols for handling non-cooperation cases. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Gerhil Medina Baez Auxiliary Administrator Operational Services

Categories

Special Tests & Provisions Eligibility Material Weakness 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
  • 1221608 2024-049
    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