Finding 1223510 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-07-09
Audit: 406864
Organization: El Paso County (CO)
Auditor: RUBINBROWN LLP

AI Summary

  • Core Issue: The County failed to conduct timely secondary reviews of eligibility determinations for Title IV-E Foster Care, risking incorrect benefit approvals.
  • Impacted Requirements: Compliance with 2 CFR Section 200.303, which mandates effective internal controls over Federal awards, particularly regarding eligibility.
  • Recommended Follow-Up: Strengthen internal control processes for eligibility reviews to ensure timely detection and correction of errors.

Finding Text

Finding 2025-002 – Material Weakness: Eligibility – Control Finding ALN 93.658 - Title IV-E Foster Care Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Colorado Department of Human Services Criteria Or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), establishes requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. Condition: A secondary review of eligibility determinations did not occur in a timely manner during 2025. Cause: Management of the program did not implement an internal control process that functioned in a timely manner. Effect: The possibility exists that an individual was incorrectly determined to be eligible to receive benefits and this error was not identified and corrected in a timely manner. Questioned Costs: Not applicable Context: Our audit of the control processes around eligibility determination for the program determined no timely review over initial determination. Identification As A Repeat Finding: N/A Recommendation: We recommend that the County strengthen the processes within the internal control framework surrounding the review of eligibility determinations for this program. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Corrective Action Plan

During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have been identified or corrected in a timely manner. Federal Regulations establish requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. The Department of Human Services (DHS) has implemented a monthly review process to audit a random sample of the IV-E cases. The review includes verification of timely and accurate determinations, client information, supporting documentation, and system entries, with results documented and approved by the reviewer. DHS Division leadership will monitor compliance to ensure the reviews are conducted each month. DHS believes this additional review procedure will provide the needed internal controls over IV-E determination.

Categories

Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $18.89M
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $15.53M
93.658 FOSTER CARE TITLE IV-E $9.15M
93.778 MEDICAL ASSISTANCE PROGRAM $8.72M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $7.34M
10.923 EMERGENCY WATERSHED PROTECTION PROGRAM $5.92M
93.659 ADOPTION ASSISTANCE $4.05M
93.563 CHILD SUPPORT SERVICES $4.00M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $2.04M
93.471 TITLE IV-E KINSHIP NAVIGATOR PROGRAM $1.56M
17.259 WIOA YOUTH ACTIVITIES $1.54M
17.258 WIOA ADULT PROGRAM $1.08M
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $937,074
93.472 TITLE IV-E PREVENTION PROGRAM $715,119
93.569 COMMUNITY SERVICES BLOCK GRANT $572,550
20.205 HIGHWAY PLANNING AND CONSTRUCTION $389,049
17.225 UNEMPLOYMENT INSURANCE $248,046
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $248,002
93.667 SOCIAL SERVICES BLOCK GRANT $247,093
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $206,157
93.090 GUARDIANSHIP ASSISTANCE $204,477
16.575 CRIME VICTIM ASSISTANCE $193,606
21.032 LOCAL ASSISTANCE AND TRIBAL CONSISTENCY FUND $181,668
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $169,347
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $152,414
10.551 SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $143,646
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $137,671
95.001 HIGH INTENSITY DRUG TRAFFICKING AREAS PROGRAM $130,000
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $129,353
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $79,283
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $73,285
97.047 BRIC: BUILDING RESILIENT INFRASTRUCTURE AND COMMUNITIES $73,099
17.207 EMPLOYMENT SERVICE/WAGNER-PEYSER FUNDED ACTIVITIES $62,715
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $56,020
93.788 OPIOID STR $52,250
90.404 HAVA ELECTION SECURITY GRANTS $41,273
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $38,053
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $35,672
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $32,904
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $29,269
16.922 EQUITABLE SHARING PROGRAM $28,874
17.801 JOBS FOR VETERANS STATE GRANTS $22,558
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $11,716