FAC Explorer

Finding 1240336 (2025-003)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-10-13
Audit: 414858
Organization: Hamilton County General Health District (OH)
Auditor: AUDITOR OF STATE OF OHIO KEITH FABER

AI Summary

  • Core Issue: Hamilton County Department of Job and Family Services (HCJFS) failed to properly manage the random moment sampling (RMS) process, leading to delays in review and approval of observations.
  • Impacted Requirements: Compliance with 45 C.F.R. § 75.430 and Ohio Admin. Code 5101:9-7-20 regarding timely responses and approvals for RMS time studies.
  • Recommended Follow-Up: HCJFS should enhance internal controls and procedures to ensure timely completion of RMS activities by Coordinators and employees.

Finding Text

45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods. 2 C.F.R. § 300.106 gives regulatory effect to the US Department of Health and Human Services and 2 C.F.R. § 2900.4 gives regulatory effect to the US Department of Labor for 2 C.F.R. § 200.405(a) which state, in part, a cost is allocable to a Federal award or other cost objective if the cost is assignable to that Federal award or other cost objective in accordance with the relative benefits received. This standard is met if the cost benefits both the Federal award and other work of the recipient or subrecipient and can be distributed in proportions that may be approximated using reasonable methods. The Ohio Department of Job and Family Services (ODJFS) and Ohio Department of Children and Youth (ODCY) have implemented a cost allocation plan approved by the US Department of Health and Human Services and communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the ODJFS and ODCY. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays. Ohio Admin. Code 5101:9-7-20(F)(3) states, in part, the RMS coordinator shall review and approve by accepting all observation moment responses within seventy-two hours. Due to the lack of controls over the random moment sampling process, the Hamilton County Department of Job and Family Services (HCJFS) did not ensure an RMS Coordinator review and approval of an observation moment was performed within 72 hours for three of 60 (10%) RMS time studies observations tested. Additionally, an employee did not respond to the RMS observation moment within 48 hours for one of the three exceptions (33%). These time studies are used to allocate expenditures across the federal programs for the county agency and failure to properly complete and approve these activities could cause incorrect charges to federal awards. The HCJFS should review its internal control policies and procedures over its RMS processes to ensure RMS activities by Coordinators and employees are performed timely.

Corrective Action Plan

All RMS’s will be accepted by RMS Coordinators within 72 hours of the observation moment. RMS coordinators will regularly complete training with RMS section chiefs, supervisors, and participants on the importance of timely completion of RMS observations. RMS coordinators will provide RMS tips and hints to participants and supervisors regarding the importance of timeliness of RMS. RMS “Passport” training will be conducted with Top Management in March of 2027. A new RMS Dashboard was created to advise Program leadership of RMS data and participant trends. RMS Supervisor validation data will be reviewed and shared with HCJFS leadership on a quarterly basis. The issues noted in RMS Audit will be shared with the RMS stakeholders. New Fiscal Analyst with be trained as RMS Backups to help ensure timeliness. The 8-minute RMS training video offered on the Beacon and an RMS “one pager” refresher was shared with RMS participants, supervisors, section chiefs on 09/08/2026. Guidance was provided to review both materials by 09/31/2026. HCJFS will implement this on a yearly basis moving forward. The RMS Supervisor and RMS Coordinators will have a better understanding to accept RMS’s timely, no matter who initially started the RMS correction conversation with the participant. The RMS Supervisor will conduct monthly spot checks of each cost pool to ensure timely completion of RMS observations.

Categories

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 1240317 2025-001
    Material Weakness Repeat
  • 1240318 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

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