Finding 1223227 (2025-001)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-07-08
Audit: 406726
Organization: Jefferson County Government (CO)

AI Summary

  • Core Issue: Inaccurate eligibility determinations for TANF due to incorrect income entries and insufficient documentation of client engagement.
  • Impacted Requirements: Compliance with federal and state eligibility criteria, including proper documentation and internal controls as mandated by the Social Security Act and Uniform Guidance.
  • Recommended Follow-Up: Enhance internal controls, provide training on income classifications, conduct regular quality assurance reviews, and implement monitoring reports for client engagement.

Finding Text

Finding: Eligibility Federal Assistance Listing Number 93.558 - Temporary Assistance for Needy Families (TANF) Federal Agency - Department of Health and Human Services, Passed-Through Colorado Department of Human Services Award Number - None Provided; Award Year 2025 Criteria or Specific Requirement: The Temporary Assistance for Needy Families (TANF) program is governed by eligibility requirements established under the Social Security Act, applicable federal regulations (45 CFR Part 260-265), and corresponding State of Colorado policies. Pursuant to Uniform Guidance at 2 CFR §200.303, the County is required to establish and maintain effective internal controls over compliance to provide reasonable assurance that TANF eligibility determinations comply with all applicable federal statutes, regulations, and the terms and conditions of the federal award. All eligibility determinations must be fully supported by complete and accurate documentation and input correctly into the Colorado Benefits Management System (CBMS). Condition: We noted the following issues in the 25 cases tested: - One instance in which client income was incorrectly entered and as such, was ineligible for benefits as they were over the income limits for all of 2025. - Three instances in which, although case notes indicated general contact with the participant, the County did not retain sufficient documentation that a required meeting specifically addressed or confirmed engagement in an eligible work activity or was completed within required timeframe. Questioned Costs: $8,169 of known questioned costs were determined by isolating the benefits issued in 2025 for the client who was over income limits. Context: We tested 25 cases that received TANF assistance for the year ended December 31, 2025, and noted the issues described above. The tested sample represented approximately $145,000 in benefits issued. The total population consisted of approximately $6.3 million in benefits issued to approximately 2,013 clients. A non-statistical sampling methodology was used to select the sample. Effect: The absence of appropriate controls related to the above requirements increases the risk of incorrect benefit payments or the provision of inappropriate services to clients. Cause: There was a misunderstanding at the staff level of subsidized and unsubsidized employment income and the implications on TANF eligibility. In addition, there was inconsistent contact between the County and clients which resulted in incomplete documentation as required by State rule and County policy. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations. This includes issuing training alerts related to the differences between subsidized and unsubsidized employment income and the impacts to eligibility. Additionally, we recommend continued periodic quality assurance reviews of TANF case files to ensure ongoing compliance with federal and state eligibility requirements and identification of employees with performance issues. Finally, we recommend the County develop monitoring reports to identify those clients who have not had a workforce contact in the required timeframe. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Corrective Action Plan

AUDITOR FINDING: 2025-001 Eligibility. We noted the following issues in the 25 cases tested: 1. One instance in which client income was incorrectly entered and as such, was ineligible for benefits as they were over the income limits for all of 2025. 2. Three instances in which, although case notes indicated general contact with the participant, the County did not retain sufficient documentation that a required meeting specifically addressed or confirmed engagement in an eligible work activity or was completed within required timeframe. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations. This includes issuing training alerts related to the differences of subsidized and unsubsidized employment income and the impacts to eligibility. Additionally, we recommend continued periodic quality assurance reviews of TANF case files to ensure ongoing compliance with federal and state eligibility requirements and identification of employees with performance issues. Finally, we recommend the County develop monitoring reports to identify those clients who have not had a workforce contact in the required timeframe. CLIENT PLANNED ACTION: Jefferson County agrees with the findings and has taken or will take the following steps to address the errors. The findings were caused by workers on both the eligibility and workforce teams so varying measures will be implemented based on the finding and responsible team. Jefferson County will continue and implement the following actions to address and prevent future findings. • Eligibility Team Actions o Jefferson County will issue a training alert to all eligibility staff by June 20, 2026, detailing the difference between subsidized and unsubsidized employment, correct data entry, and the impact of each on TANF eligibility. o To monitor compliance, the County will continue completing Internal Quality Assurance reviews utilizing the state mandated list to assess the case and payment accuracy. • Workforce Development Team Actions o Performance concerns related to inconsistent client contact and incomplete documentation were identified during regular performance reviews in January 2026 and have been successfully addressed via the county Employee Relations coaching and disciplinary framework. •To monitor compliance, the County will continue completing Internal Quality Assurance reviews utilizing the state mandated list. In addition, Colorado Works Supervisors review at least one case per worker each month. Beginning in June 2026, the number will be increased to a minimum of 10 cases per month if a performance concern is identified. o Tableau reports have been created or enhanced to monitor compliance. • Individual case worker accuracy reports for all IQA and Supervisor reviews were released in March 2026. Progress reviews have been incorporated into monthly supervision meetings with staff. • Enhancement to report titled, Cases Needing Action, which tracks data entry of client contact and Individual Plan development in CBMS was completed on June 1, 2026. Workers will now be notified if client contact exceeds 30 days. Workers and supervisors will review the report monthly and take proactive measures for client contact prior to exceeding rule requirement of 90 days. CLIENT RESPONSIBLE PARTY: CW Eligibility Team: Julia Zoukhri (Program Manager), Brandy Brogan (Program Manager), Karen Thomas (Program Manager) and Jennifer Martinez (Quality Assurance & Systems Administrator) CW Workforce Development Team: Tara Noble (Program Manager), Kathryn Boyd-Cordova (CW Supervisor), and Erin Encinias (CW Supervisor) COMPLETION DATE: July 2026

Categories

Eligibility Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $8.94M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $7.05M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $6.73M
93.778 GRANTS TO STATES FOR MEDICAID $6.72M
93.600 HEAD START $6.37M
20.106 AIRPORT IMPROVEMENT PROGRAM $5.42M
93.658 FOSTER CARE TITLE IV-E $4.75M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $4.63M
93.563 CHILD SUPPORT SERVICES $4.38M
93.659 ADOPTION ASSISTANCE $2.64M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $2.30M
93.667 SOCIAL SERVICES BLOCK GRANT $1.72M
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $1.41M
16.576 CRIME VICTIM COMPENSATION $1.38M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $1.29M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $1.28M
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $962,985
17.207 EMPLOYMENT SERVICE/WAGNER-PEYSER FUNDED ACTIVITIES $704,127
93.471 TITLE IV-E KINSHIP NAVIGATOR PROGRAM $669,889
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $661,283
17.258 WIOA ADULT PROGRAM $590,623
17.259 WIOA YOUTH ACTIVITIES $569,137
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $514,864
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $501,097
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $486,633
17.225 UNEMPLOYMENT INSURANCE $474,933
93.569 COMMUNITY SERVICES BLOCK GRANT $444,259
16.575 CRIME VICTIM ASSISTANCE $426,412
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $401,624
16.922 EQUITABLE SHARING PROGRAM $356,427
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $333,247
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $304,414
93.472 Title IV-E Prevention Services $303,610
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $267,367
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $236,260
15.226 PAYMENTS IN LIEU OF TAXES (PILT) $233,449
10.923 EMERGENCY WATERSHED PROTECTION PROGRAM $226,230
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $217,736
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $214,619
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $210,133
17.270 REENTRY EMPLOYMENT OPPORTUNITIES $196,551
20.939 SAFE STREETS AND ROADS FOR ALL $182,499
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $175,888
93.788 OPIOID STR $174,241
21.032 LOCAL ASSISTANCE AND TRIBAL CONSISTENCY FUND $174,145
16.741 DNA BACKLOG REDUCTION PROGRAM $132,364
16.036 COMPREHENSIVE FORENSIC DNA ANALYSIS GRANT PROGRAM $125,873
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $118,779
10.558 CHILD AND ADULT CARE FOOD PROGRAM $111,142
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $110,164
15.437 MINERALS LEASING ACT $82,519
10.551 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $81,429
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $76,670
10.723 COMMUNITY PROJECT FUNDS - CONGRESSIONALLY DIRECTED SPENDING $74,399
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $73,284
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $68,212
93.090 GUARDIANSHIP ASSISTANCE $63,266
66.605 PERFORMANCE PARTNERSHIP GRANTS $44,451
97.039 HAZARD MITIGATION GRANT $41,412
93.977 SEXUALLY TRANSMITTED DISEASES (STD) PREVENTION AND CONTROL GRANTS $30,643
10.665 SCHOOLS AND ROADS - GRANTS TO STATES $29,217
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $27,020
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT $26,986
21.016 EQUITABLE SHARING $26,931
66.034 SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS, AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT $26,888
17.801 JOBS FOR VETERANS STATE GRANTS $25,432
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $21,261
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $17,535
93.317 EMERGING INFECTIONS PROGRAMS $14,613
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $11,540
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $3,300
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2,851
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $-59,957