Finding 1222668 (2025-006)

Finding 2025-006 Assistance Listing Number(s): 93.558 Name of Federal Program or Cluster: Temporary Assistance for Needy Families 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, 2024 through June 30, 2025 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. Internal controls should be designed and implemented to ensure that eligibility determinations are supported with appropriate documentation, reflect current eligibility, and are reviewed and approved prior to the provision of assistance. Condition and Context: Testing of 11 out of 70 participant eligibility files disclosed significant deficiencies in documentation and internal control over eligibility determinations, as follows: • Internal Control Review o 11 of 11 files lacked documentation evidencing a supervisory or secondary review of eligibility determinations and supporting documentation. • Financial Eligibility o 6 of 11 files lacked adequate support for financial eligibility, including:  3 files with no supporting documentation, and  3 files with documentation from a prior year with no evidence of recertification. • Citizenship or Qualified Alien Status o 6 of 11 files lacked sufficient documentation, including:  3 files with no documentation, and  3 files with only a driver’s license provided. These documents do not establish U.S. citizenship or qualified alien status. • TANF Benefit History o 11 of 11 files lacked documentation verifying prior TANF benefit history to support compliance with the 60-month lifetime limit. • Household Composition o 11 of 11 files lacked documentation demonstrating that a minor child resided in the household with the parent or caretaker relative. • Legal Eligibility Requirements o 11 of 11 files lacked documentation supporting compliance with applicable federal and state eligibility requirements, including restrictions related to legal disqualifications, where applicable. • Work Participation o 6 of 11 files lacked adequate support, including:  4 files with no documentation, and  2 files with documentation from a prior year with no evidence of recertification. Cause: The deficiencies were caused by inadequate internal controls over TANF eligibility determinations and documentation. The entity did not have sufficiently detailed written procedures identifying required documentation for each eligibility criterion, nor did it ensure documentation was current and maintained in participant files. In addition, a formal supervisory review process was not implemented. As a result, staff 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, the entity 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. Repeat Finding: This finding is a repeat of 2024-003. 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.