Finding Text
Assistance Listing Number: 93.558 Name of Federal Program or Cluster: Temporary Assistance for Needy Families (TANF) Name of Federal Agency: Department of Health and Human Services Name of Pass-Through Entity: Virginia Department of Social Services Pass-Through Entity Identifying Number: BEN-21-029 Award Period: July 1, 2023 through June 30, 2024 Criteria or Specific Requirement: Federal TANF requirements provide that assistance be made only to eligible families, which generally must include a financially needy household with a dependent child and a parent or caretaker relative, and must meet applicable eligibility requirements, including citizenship or qualified alien status. Eligibility determinations must be supported by sufficient documentation demonstrating compliance with program requirements. In addition, internal controls should be designed and implemented to ensure that: Eligibility determinations are supported with appropriate documentation, Eligibility determinations are reviewed and approved prior to the provision of assistance. Condition and Context: Testing of 12 participant eligibility files disclosed material weaknesses in documentation and internal control over eligibility determinations, as follows: Internal Control Review o 11 of 12 files lacked documentation evidencing a supervisory or secondary review of eligibility determinations and supporting documentation. Financial Eligibility o 6 of 12 files lacked current-year documentation supporting financial need, and no evidence of annual recertification was maintained. Citizenship or Qualified Alien Status o 8 of 12 files lacked sufficient documentation supporting U.S. citizenship or qualified alien status. Files contained only: An employment authorization card, A Social Security card stating “valid for work only with DHS authorization,” A Social Security card with no restriction noted, or No supporting documentation. These documents do not establish U.S. citizenship or qualified alien status. TANF Benefit History o 12 of 12 files lacked documentation verifying prior TANF benefit history to support compliance with the 60-month lifetime limit on federally funded TANF assistance. Household Composition o 9 of 12 files lacked documentation demonstrating that a minor child resided in the household with the parent or caretaker relative. Legal Disqualifications o 12 of 12 files lacked documentation supporting compliance with applicable federal and state eligibility requirements, including restrictions related to legal disqualifications, where applicable. Work Participation o 7 of 12 files lacked documentation supporting that participants were engaged in required work activities, when applicable. Cause: The deficiencies were caused by inadequate internal controls over TANF eligibility determinations and documentation. Specifically, UCM did not have sufficiently detailed written procedures identifying the documentation required to support each eligibility requirement, including financial eligibility, citizenship or qualified alien status, household composition, TANF benefit history, compliance with applicable legal eligibility requirements, and work participation. In addition, a formal process requiring supervisory review and approval of eligibility determinations and supporting documentation was not consistently implemented. As a result, staff responsible for determining eligibility did not consistently obtain, update, and retain documentation necessary to demonstrate compliance with federal TANF eligibility requirements. Effect or Potential Effect: Due to these deficiencies, UCM cannot demonstrate that TANF assistance was provided only to eligible participants, increasing the risk that assistance may have been provided to individuals who did not meet program eligibility requirements. Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant files include sufficient documentation supporting financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, compliance with applicable legal eligibility requirements, and work participation when applicable. In addition, the entity should implement a documented supervisory review and approval process to verify eligibility determinations and supporting documentation prior to the provision of assistance. The entity should also provide training to staff responsible for eligibility determinations to ensure they understand federal TANF documentation requirements and maintain complete and accurate participant files. Views of Responsible Officials: Management acknowledges the finding and will work to implement appropriate corrective actions to address the deficiency and improve compliance going forward.