Finding 1238146 (2025-003)

The Revenue Support Services (RSS) grant agreement between the Ohio Department of Job and Family Services (ODJFS) and the Franklin County Department of Job and Family Services (the County) states in Article I, Subgrant Activities, that copies of the signed Acknowledgement of Rights and Responsibilities form must be maintained in participant profiles. The form must be acknowledged by the participant, the caseworker, and the interpreter when the form was not translated into the participant's primary language. Additionally, Article I requires the participant's self-sufficiency contract to be reviewed every six months and a follow-up assessment of the participant's progress toward established goals to be completed and documented. Furthermore, Appendix B of the Franklin County Department of Job and Family Services Purchase of Service Subaward Agreements (the subaward agreement) require employment counseling, employer collaboration, and employment tracking every six and twelve months. For programs audited on or after October 1, 2025 2 CFR § 300.106 gives regulatory effect to the Department of Health and Human Services for 2 CFR § 200.332(e), which states, in part, that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals and objectives are achieved. For programs audited on or before September 30, 2025 45 CFR § 75.352(d) states in part that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The County did not have adequate internal controls in place to ensure its subrecipients complied with the requirements of the RSS grant and subaward agreements and did not adequately monitor subrecipient compliance with these requirements. During our testing of 60 participant packets maintained by the County's subrecipients, we noted the following: • Nine (9) of 60 (15%) participant packets tested did not contain the participant's signature on the RSS Acknowledgement of Rights and Responsibilities form, as required by Article I of the RSS grant agreement. • Five (5) of 60 (8%) participant packets tested did not contain documentation that the required six-month and/or twelve-month follow-up assessments were completed after the participant's initial enrollment, as required by Article I of the RSS grant agreement and Appendix B of the subaward agreement. The County's failure to adequately monitor its subrecipients contributed to these instances of noncompliance not being identified and corrected in a timely manner. Failure to obtain and maintain required participant acknowledgements increase the risk that participants may not fully understand program requirements, their rights and responsibilities, or the consequences of noncompliance. Failure to complete and document required follow-up assessments increases the risk that participant progress toward established self-sufficiency goals is not adequately monitored. Additionally, inadequate subrecipient monitoring increases the risk that noncompliance with federal requirements and the terms and conditions of the RSS grant agreement may occur and remain undetected, which could result in questioned costs, repayment of grant funds, or other corrective action by the grantor. We recommend the County establish and implement procedures to adequately monitor its RSS subrecipients for compliance with applicable federal requirements and the terms and conditions of the RSS grant and subaward agreements. Monitoring procedures should include a review of participant files to ensure required acknowledgements are obtained and maintained and required follow-up assessments are completed and documented. The County should document the monitoring performed, communicate identified deficiencies to its subrecipients, and follow up to ensure corrective action is taken in a timely manner. Officials’ Response: Refer to corrective action plan.