Finding 1238604 (2025-002)

2025-002 Special Tests and Provisions – Child Support Non-Cooperation Prior Year Finding Number: 2024-003 Year of Finding Origination: 2024 Type of Finding: Internal Control Over Compliance and Compliance Severity of Deficiency: Material Weakness and Modified Opinion Federal Agency: U.S. Department of Health and Human Services Program: 93.558 Temporary Assistance for Needy Families Award Number and Year: 2501MNTANF; 2025 Pass-Through Agency: Minnesota Department of Human Services Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish, document, and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Title 45 U.S. Code of Federal Regulations § 264.30 states: “What procedures exist to ensure cooperation with the child support enforcement requirements? (a)(1) The State agency must refer all appropriate individuals in the family of a child, for whom paternity has not been established or for whom a child support order needs to be established, modified, or enforced, to the child support enforcement agency (i.e., the IV-D agency). (2) Referred individuals must cooperate in establishing paternity and in establishing, modifying, or enforcing a support order with respect to the child. (b) If the IV-D agency determines that an individual is not cooperating, and the individual does not qualify for a good cause or other exception established by the State agency responsible for making good cause determinations in accordance with section 454(29) of the Act or for a good cause domestic violence waiver granted in accordance with § 260.52 of this chapter, then the IV-D agency must notify the IV-A agency promptly. (c) The IV-A agency must then take appropriate action by: (1) Deducting from the assistance that would otherwise be provided to the family of the individual an amount equal to not less than 25 percent of the amount of such assistance; or (2) Denying the family any assistance under the program.” Condition: Eligibility requirements include cooperating with child support. When a recipient is determined to be in non-cooperation status by the child support agency, counties are required to reduce benefits accordingly. The following exceptions were noted in the sample of six recipient files with non-cooperation in establishing paternity tested: • One recipient file did not have a child support non-cooperation letter included in supporting documentation; • One recipient file had sanctions that should have begun in July; however, the non-cooperation letter was not issued until September 17, 2025. Sanctions were applied in September but are supposed to be applied in the month subsequent to the non-cooperation letter; and • One recipient file had sanctions imposed on October 1, 2025. The client came into compliance on October 3, 2025, and had sanctions lifted in October; however, sanctions should have instead been lifted in November. Questioned Costs: Not applicable. The County administers the program, but the State of Minnesota pays benefits to recipients in this program. Context: Child support non-cooperation is determined by Ramsey County, and the Providing Resources to Improve Support in Minnesota (PRISM) system maintains the information and recipient status. When a Child Support Officer at the County updates PRISM to show non-cooperation, it interfaces with MAXIS. From this interface, MAXIS receives a Worker’s Daily Report message which notifies the entity of child support non-cooperation. The County is responsible for updating the recipient’s record in MAXIS, including entering child support sanctions, or closing a recipient file on the seventh occurrence of noncompliance. The total population of recipients subject to child support non-cooperation for this program was 54; the sample size was 6 recipients. The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Effect: Benefit overpayments or underpayments could be paid when child support non-cooperation is not properly processed for a benefit month. Cause: Program personnel entering recipient data into MAXIS did not ensure all required information was input correctly, supported, and retained. Recommendation: We recommend Ramsey County implement additional procedures to provide reasonable assurance that child support non-cooperation benefits are being reduced as necessary in MAXIS. In addition, Ramsey County should consider providing further training to program personnel. View of Responsible Official: Concur