Finding 1240318 (2025-001)

Material Weakness Repeat Finding
Requirement
G
Questioned Costs
-
Year
2025
Accepted
2026-10-13

AI Summary

  • Core Issue: The County used only 15.93% of Youth Activity funds for required work experiences, falling short of the 20% minimum.
  • Impacted Requirements: Failure to meet the earmarking requirements of 29 USC § 3164(c)(4) could jeopardize federal funding and lead to legal repercussions.
  • Recommended Follow-up: Implement monitoring procedures to ensure compliance with earmark requirements throughout the year.

Finding Text

29 USC § 3164(c)(4) states, in part, not less than 20 percent of [Youth Activity] funds allocated to the local area shall be used to provide in-school youth and out-of-school youth with [paid and unpaid work experiences that have a component of academic and occupational education, as described in 29 USC § 3164(c)(2)(C)]. 20 CFR § 681.590 states, in part, local area administrative costs are not subject to the 20 percent minimum work experience expenditure requirement. The County did not have procedures in place to monitor and ensure that federal earmarking requirements were being met. The County used 15.93 percent of the allocated Youth Activity funds, except for the local area expenditures for administration, to provide paid and unpaid work experiences. Failure to comply with USC earmark requirements for federal programs could result in complications with regard to receiving federal funding and legal issues potentially involving having to repay the funds used. The County should implement policies and procedures to monitor and track program expenditures against legally mandated earmark requirements through the course of the year to ensure that earmarking requirements are being met.

Corrective Action Plan

Hamilton County Job and Family Services (HCJFS) has implemented a review procedure to monitor and ensure that federal earmarking requirements are met and has utilized it for several program years. The HCJFS review procedure was utilized during Program Year 2024 (7/1/24 to 6/30/25), as shown in the spreadsheet listed below, to ensure that no less than 20 percent of Youth Activity funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences as addressed in 29 USC 3164(c)(4). HCJFS typically tracks Work Experience spending across a program year and not a calendar year, but these tools can be adjusted to accommodate the tracking of calendar year spending. This tool will allow HCJFS to closely monitor to ensure these requirements are met and determine when corrective action needs to be taken with the provider to increase Work Experience spending.

Categories

Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1240317 2025-001
    Material Weakness Repeat
  • 1240319 2025-002
    Material Weakness Repeat
  • 1240320 2025-002
    Material Weakness Repeat
  • 1240321 2025-002
    Material Weakness Repeat
  • 1240322 2025-002
    Material Weakness Repeat
  • 1240323 2025-003
    Material Weakness Repeat
  • 1240324 2025-003
    Material Weakness Repeat
  • 1240325 2025-003
    Material Weakness Repeat
  • 1240326 2025-003
    Material Weakness Repeat
  • 1240327 2025-003
    Material Weakness Repeat
  • 1240328 2025-003
    Material Weakness Repeat
  • 1240329 2025-003
    Material Weakness Repeat
  • 1240330 2025-003
    Material Weakness Repeat
  • 1240331 2025-003
    Material Weakness Repeat
  • 1240332 2025-003
    Material Weakness Repeat
  • 1240333 2025-003
    Material Weakness Repeat
  • 1240334 2025-003
    Material Weakness Repeat
  • 1240335 2025-003
    Material Weakness Repeat
  • 1240336 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $14.81M
93.778 GRANTS TO STATES FOR MEDICAID $5.75M
93.563 CHILD SUPPORT SERVICES $4.94M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $4.17M
93.659 ADOPTION ASSISTANCE $3.63M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $2.42M
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $882,672
17.259 WIOA YOUTH ACTIVITIES $852,912
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $827,841
93.658 FOSTER CARE TITLE IV-E $741,457
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $674,014
66.001 AIR POLLUTION CONTROL PROGRAM SUPPORT $594,567
93.471 TITLE IV-E KINSHIP NAVIGATOR PROGRAM $575,295
93.667 SOCIAL SERVICES BLOCK GRANT $550,400
16.745 CRIMINAL AND JUVENILE JUSTICE AND MENTAL HEALTH COLLABORATION PROGRAM $473,665
17.258 WIOA ADULT PROGRAM $471,040
16.741 DNA BACKLOG REDUCTION PROGRAM $367,815
66.034 SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS, AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT $334,886
16.842 OPIOID AFFECTED YOUTH INITIATIVE $330,203
97.052 EMERGENCY OPERATIONS CENTER $317,075
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $311,254
97.067 HOMELAND SECURITY GRANT PROGRAM $303,852
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $299,278
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $283,513
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $238,292
10.935 URBAN AGRICULTURE AND INNOVATIVE PRODUCTION GRANTS PROGRAM (UAIP) $213,180
16.828 SWIFT, CERTAIN, AND FAIR SUPERVISION PROGRAM: APPLYING THE PRINCIPLES BEHIND PROJECT HOPE $199,593
17.278 WIOA DISLOCATED WORKER FORMULA GRANTS $190,849
97.091 HOMELAND SECURITY BIOWATCH PROGRAM $172,670
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $172,469
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $156,952
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $130,484
20.940 RECONNECTING COMMUNITIES PILOT (RCP) DISCRETIONARY GRANT PROGRAM $120,999
16.838 COMPREHENSIVE OPIOID, STIMULANT, AND SUBSTANCE USE PROGRAM $119,872
16.836 INDIGENT DEFENSE $111,294
16.585 TREATMENT COURT DISCRETIONARY GRANT PROGRAM $109,425
93.472 TITLE IV-E PREVENTION PROGRAM $108,449
16.554 NATIONAL CRIMINAL HISTORY IMPROVEMENT PROGRAM (NCHIP) $87,496
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $68,254
10.553 SCHOOL BREAKFAST PROGRAM $64,787
20.703 INTERAGENCY HAZARDOUS MATERIALS PUBLIC SECTOR TRAINING AND PLANNING GRANTS $61,340
16.742 PAUL COVERDELL FORENSIC SCIENCES IMPROVEMENT GRANT PROGRAM $52,087
84.027 SPECIAL EDUCATION GRANTS TO STATES $45,114
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $44,436
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $40,693
17.207 EMPLOYMENT SERVICE/WAGNER-PEYSER FUNDED ACTIVITIES $38,745
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $37,307
10.555 NATIONAL SCHOOL LUNCH PROGRAM $36,877
17.277 WIOA NATIONAL DISLOCATED WORKER GRANTS / WIA NATIONAL EMERGENCY GRANTS $35,805
16.320 SERVICES FOR TRAFFICKING VICTIMS $35,028
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $27,984
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $25,376
20.205 HIGHWAY PLANNING AND CONSTRUCTION $20,714
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $18,950
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $13,587
93.788 OPIOID STR $12,067
17.225 UNEMPLOYMENT INSURANCE $10,064
93.747 ELDER ABUSE PREVENTION INTERVENTIONS PROGRAM $9,814
97.137 STATE AND LOCAL CYBERSECURITY GRANT PROGRAM TRIBAL CYBERSECURITY GRANT PROGRAM $7,106
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $4,022
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $3,691
93.090 GUARDIANSHIP ASSISTANCE $3,497
17.245 TRADE ADJUSTMENT ASSISTANCE $444