Finding Text
2022-001 - U.S. Department of Health and Human Services - Nebraska Department of Labor ? Temporary Assistance for Needy Families ? 93.558 Criteria or Specific Requirement ? Management is responsible for implementing and effectively operating internal controls over compliance to mitigate the risk of misuse of the Organization?s federal funds and ensure participating students are eligible based on financial need. The Temporary Assistance for Needy Families (TANF) funds may be used for expenses related to Job?s for America?s Graduates (JAG) Program, which helps low-income students with additional resources in middle and/or high school to help the students graduate. To be eligible for the JAG Program, which is funded by the TANF funds, the students must be low-income, evidenced by qualification for free or reduced lunch. Condition ? Two students were identified by the auditor in relation to the eligibility compliance requirement that were either: a) not eligible for the program, or b) had no support proving the student was eligible to participant in the program. The low-income student participation percentages applied to JAG Program costs were overstated based on the one ineligible student identified. This percentage is used to determine TANF eligible JAG Program expenses, which as result were overstated. Questioned Costs ? Questioned costs are unknown due to the complexity of the monthly low-income student participation percentage applied to school specific costs resulting in the TANF eligible JAG program expenses. Context ? Out of a population of 856 participating students, FORVIS selected 40 for testing. There were 2 students that were either a) not eligible for the program or b) had no support proving the student was eligible to participant in the program. This impacts the low-income student participation percentage used in the calculation of JAG Program related allowable costs. Effect ? The low-income student participation percentages applied to JAG Program costs charged to the TANF grant were overstated. Cause ? JAG Program policies implemented by United Way of the Midlands, including documentation retention, were not adhered to. ecommendation ? Management should consider changes to their JAG Program policies, including documentation requirements and retention, as well as perform a more detailed review of student?s eligibility to ensure the low-income student participation percentage is correctly stated and applied to JAG program expenses each month to properly calculate TANF allowable costs. View of Responsible Officials and Planned Correction Action - United Way of the Midlands (UWM) has reviewed and updated its policies, procedures and training within the JAG Program to improve retention of eligibility documentation and, in the event such documentation is no longer available, document the validation of eligibility requirements used to support Management?s decision on the applicant?s eligibility. This is fully documented in our Quality Assurance SOP (Standard Operating Procedures). UWM also implemented an additional detective internal control in our JAG Nebraska Invoicing SOP that requires a UWM Finance member independent of the eligibility onboarding process to audit monthly a small sampling of students for proper documentation and eligibility related to TANF invoicing. Management will monitor this regularly throughout the year to ensure procedures are being followed as documented. All changes have been implemented.