Finding 391663 (2023-008)

Material Weakness Repeat Finding
Requirement
ABE
Questioned Costs
$1
Year
2023
Accepted
2024-04-01
Audit: 302108
Organization: Department of Human Services (HI)
Auditor: Accuity LLP

AI Summary

  • Core Issue: There are significant compliance failures in the adoption assistance program, leading to questioned costs of $9,527.
  • Impacted Requirements: Missing documentation and approvals violate federal laws regarding eligibility and assistance determinations.
  • Recommended Follow-Up: Ensure staff are trained on grant requirements and strictly adhere to established policies and procedures.

Finding Text

Finding No. 2023 008: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Questioned cost: $ 9,527 Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.659 and COVID 19 – 93.659 – Adoption Assistance Award Number and Award Year: 2201HIADPT 2022 2301HIADPT 2023 Repeat Finding? Yes Condition We selected a non statistical sample of 60 case files which approximated $44,000 in monthly benefit payments, out of a population of approximately 2,300 case files totaling $14.2 million in annual benefit payments, for testing and noted exceptions in 20 case files as follows: • 16 case files where the initial or modified adoption agreement was missing and therefore did not have any support for the amount of monthly assistance paid. • Two case files where the State, Federal Bureau of Investigation (“FBI”), and/or child abuse and neglect clearances were missing. • Two case files where the “difficulty of care” determination was missing and therefore did not have any support for the assistance amount paid. • Four case files where the supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents was missing. • One case file where the final approval was granted to a household with an individual who was convicted of spousal abuse. • One case file where the adoption decree was missing from the case records. • One case file where the income eligibility test was missing from the case records. Criteria Pursuant to 42 USC 673(a)(3), the amount of the adoption assistance payments to be made shall be determined through agreement between the adoptive parents and the State or local agency administering the program, which shall take into consideration the circumstances of the adopting parents and the needs of the child being adopted, and may be readjusted periodically, with the concurrence of the adopting parents (which may be specified in the adoption assistance agreement), depending upon changes in such circumstances. Pursuant to 42 USC 671(a)(20)(A), the State must have procedures for criminal records checks, including a fingerprint-based check of national crime information databases (as defined in 28 USC 534(f)(3)(A)), for any prospective adoptive parent before the adoptive parent may be finally approved for placement of a child. Pursuant to 42 USC 671(a)(20)(B), the State shall check any child abuse and neglect registry maintained by the State for information on any prospective foster or adoptive parent and on any other adult living in the home of such a prospective parent. Pursuant to 42 USC 673(a)(2)(A), the State must determine the child to have special needs to be eligible for adoption assistance payments. Pursuant to 42 USC 673(c)(1), the State must determine whether the child cannot or should not be returned to the home of his or her parents. Pursuant to 42 USC 671(a)(20)(A)(i), in any case involving a child on whose behalf such payments are to be so made in which a record check reveals a felony conviction for spousal abuse, such final approval shall not be granted. Pursuant to 42 USC 675(3), the agreement for the adoption subsidy must be signed before the final decree of adoption and contains information concerning the nature of services. Pursuant to 42 USC 673(a)(2)(D), if an adopted child received Title IV E guardianship assistance payments, the Title IV E agency would apply the adoption assistance criteria for the child as if the guardianship never occurred. Effect Failure to follow the established policies and procedures in place over the application process and determination of assistance amount represents an instance of noncompliance with the requirements of 2 CFR Part 200, resulting in questioned costs. Cause and View of Responsible Officials Although the Department has established policies and procedures in place regarding the application process and determination of assistance amount, there was a lack of diligence in complying with the policies and procedures. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200. Additionally, we recommend that the Department diligently comply with its policies and procedures.

Corrective Action Plan

Views of Responding Officials: The Department agrees with the finding and will implement corrective action; however, notes the following: Adoption Assistance is an incentive program with payment beginning prior to the finalization of an adoption. The adoption decree is not required for payment as the Adoption Assistance Agreement must be entered into prior to the finalization of an adoption. Corrective Action Taken or Planned: 1. Child Welfare Service (“CWS”) staff will be informed of the audit findings, the importance of diligent compliance of policies and procedures, records maintenance and this corrective action plan. 2. Unit staff (Licensing, CWS, and FPPEU) who manage cases identified with errors in this audit will be retrained, ensuring familiarity with grant requirements and related policies and procedures. • Staff will be given coaching/supervisory support to correctly complete documentation. 3. Case specific audit findings and corrective action taken will be noted in each record where there was a finding. • Research/review and document why licensing approval was granted to a household with an individual who was convicted of spousal abuse. i. If review determines that Adoption Assistance Agreement (“AAA”) was inappropriately authorized, provide family with an adverse action notice discontinuing the AAA and explaining the appeals process. • Investigate whether supporting documentation regarding whether the State determined that the child cannot or should not be returned to the home of his or her parents can be located and added to the record. • Secure a copy of the missing adoption decree, although adoption assistance is an incentive program with payment beginning prior to the finalization of an adoption. • Document the qualifying need for Difficulty of Care (“DOC”) determination for the records, showing how DOC was calculated. • Document how income eligibility was verified. • Secure missing modified adoption agreements. • Locate missing clearances or re run them if not located. Note: Not all clearances are secured prior to placement; FBI clearances come later and are NOT required prior to placement in a “provisionally licensed” home. 4. The identified errors and the related corrective action steps proposed above will be reviewed by CWS Administrators, staff supervisors, and the Management Information Compliance Unit (“MICU”) within 90 days to ensure missing documentation has been secured and/or properly noted in record. 5. MICU staff will audit records with findings to ensure errors have been documented and corrected. • MICU will work with Branch Administrators, Social Services Assistants (“SSA”), and program personnel to ensure file updates with completion of missing information. 6. As CWS implements this corrective action plan and monitors the results, the action steps proposed in 1 – 5 may be modified, based on input from CWS Administrators or exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2024 and on going Responding Officials: Kisha C. Raby, Social Services Division, Child Welfare Services Program Development Office, Administrator, and Tonia Mahi, Social Services Division, Child Welfare Services Program Development Office, Assistant Branch Administrator

Categories

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles Eligibility Material Weakness

Other Findings in this Audit

  • 391661 2023-010
    Material Weakness Repeat
  • 391662 2023-010
    Material Weakness Repeat
  • 391664 2023-008
    Material Weakness Repeat
  • 391665 2023-009
    Material Weakness Repeat
  • 391666 2023-009
    Material Weakness Repeat
  • 391667 2023-017
    Significant Deficiency
  • 391668 2023-006
    Significant Deficiency Repeat
  • 391669 2023-011
    Material Weakness Repeat
  • 391670 2023-011
    Material Weakness Repeat
  • 391671 2023-012
    Material Weakness Repeat
  • 391672 2023-012
    Material Weakness Repeat
  • 391673 2023-013
    Material Weakness Repeat
  • 391674 2023-013
    Material Weakness Repeat
  • 391675 2023-014
    Significant Deficiency Repeat
  • 391676 2023-014
    Significant Deficiency Repeat
  • 391677 2023-015
    Material Weakness Repeat
  • 391678 2023-015
    Material Weakness Repeat
  • 391679 2023-016
    Material Weakness Repeat
  • 391680 2023-016
    Material Weakness Repeat
  • 391681 2023-007
    Significant Deficiency Repeat
  • 391682 2023-007
    Significant Deficiency Repeat
  • 391683 2023-007
    Significant Deficiency Repeat
  • 391684 2023-003
    Significant Deficiency Repeat
  • 391685 2023-003
    Significant Deficiency Repeat
  • 391686 2023-003
    Significant Deficiency Repeat
  • 391687 2023-004
    Material Weakness Repeat
  • 391688 2023-004
    Material Weakness Repeat
  • 391689 2023-004
    Material Weakness Repeat
  • 391690 2023-005
    Material Weakness Repeat
  • 391691 2023-005
    Material Weakness Repeat
  • 391692 2023-005
    Material Weakness Repeat
  • 968103 2023-010
    Material Weakness Repeat
  • 968104 2023-010
    Material Weakness Repeat
  • 968105 2023-008
    Material Weakness Repeat
  • 968106 2023-008
    Material Weakness Repeat
  • 968107 2023-009
    Material Weakness Repeat
  • 968108 2023-009
    Material Weakness Repeat
  • 968109 2023-017
    Significant Deficiency
  • 968110 2023-006
    Significant Deficiency Repeat
  • 968111 2023-011
    Material Weakness Repeat
  • 968112 2023-011
    Material Weakness Repeat
  • 968113 2023-012
    Material Weakness Repeat
  • 968114 2023-012
    Material Weakness Repeat
  • 968115 2023-013
    Material Weakness Repeat
  • 968116 2023-013
    Material Weakness Repeat
  • 968117 2023-014
    Significant Deficiency Repeat
  • 968118 2023-014
    Significant Deficiency Repeat
  • 968119 2023-015
    Material Weakness Repeat
  • 968120 2023-015
    Material Weakness Repeat
  • 968121 2023-016
    Material Weakness Repeat
  • 968122 2023-016
    Material Weakness Repeat
  • 968123 2023-007
    Significant Deficiency Repeat
  • 968124 2023-007
    Significant Deficiency Repeat
  • 968125 2023-007
    Significant Deficiency Repeat
  • 968126 2023-003
    Significant Deficiency Repeat
  • 968127 2023-003
    Significant Deficiency Repeat
  • 968128 2023-003
    Significant Deficiency Repeat
  • 968129 2023-004
    Material Weakness Repeat
  • 968130 2023-004
    Material Weakness Repeat
  • 968131 2023-004
    Material Weakness Repeat
  • 968132 2023-005
    Material Weakness Repeat
  • 968133 2023-005
    Material Weakness Repeat
  • 968134 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $2.17B
10.551 Supplemental Nutrition Assistance Program $895.39M
10.542 Pandemic Ebt Food Benefits $74.01M
93.767 Children's Health Insurance Program $52.88M
93.558 Temporary Assistance for Needy Families $42.41M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $32.90M
15.875 Economic, Social, and Political Development of the Territories $31.60M
21.027 Coronavirus State and Local Fiscal Recovery Funds $22.37M
93.575 Child Care and Development Block Grant $20.71M
93.658 Foster Care_title IV-E $14.69M
93.659 Adoption Assistance $14.28M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $14.28M
93.667 Social Services Block Grant $14.01M
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $10.26M
96.001 Social Security_disability Insurance $7.51M
93.568 Low-Income Home Energy Assistance $5.80M
93.090 Guardianship Assistance $3.88M
93.556 Promoting Safe and Stable Families $1.60M
93.645 Stephanie Tubbs Jones Child Welfare Services Program $1.21M
10.649 Pandemic Ebt Administrative Costs $1.18M
93.777 State Survey and Certification of Health Care Providers and Suppliers (title Xviii) Medicare $1.00M
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $988,169
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $607,471
93.464 Acl Assistive Technology $540,376
14.231 Emergency Solutions Grant Program $487,588
94.011 Foster Grandparent Program $348,625
93.669 Child Abuse and Neglect State Grants $346,420
93.747 Elder Abuse Prevention Interventions Program $310,287
14.241 Housing Opportunities for Persons with Aids $301,602
93.599 Chafee Education and Training Vouchers Program (etv) $218,511
94.016 Senior Companion Program $218,350
93.603 Adoption Incentive Payments $206,000
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $124,281
93.643 Children's Justice Grants to States $110,892
10.545 Farmersõ Market Supplemental Nutrition Assistance Program Support Grants $18,960
93.566 Refugee and Entrant Assistance_state Administered Programs $16,330
84.187 Supported Employment Services for Individuals with the Most Significant Disabilities $16,037
93.369 Acl Independent Living State Grants $16,000
10.537 Supplemental Nutrition Assistance Program (snap) Employment and Training (e&t) Data and Technical Assistance Grants $4,892
84.177 Rehabilitation Services_independent Living Services for Older Individuals Who Are Blind $588