Finding 399920 (2022-002)

Foster Care and Adoption Assistance Random Moment Sampling Finding Number: 2022-002 CFDA Number and Title: AL#93.658 - Foster Care-Title IV-E AL#93.659 - Adoption Assistance Federal Award Identification Number / Year: G-2022-11-5932 / G-2022-06-0057 / G-2223-11-5932 / G-2223-11-6932 Federal Agency: U.S. Department of Health and Human Services Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principles Pass-Through Entity: Ohio Department of Jobs and Family Services Repeat Finding from Prior Audit? YesNoncompliance and Material Weakness 45 C.F.R. § 75.405 (a) states, in part, 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 the relative benefits received. In order for a cost 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. In addition, Ohio Admin. Code 5101:9-7-20(E) outlines the procedures to be utilized for random moment sampling time studies (RMS) designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services including those administered through the public Children Services Agency. These procedures include an employee completing the required comments section, within WebRMS, with comments that demonstrate that the selected program and activity codes supporting the work performed by the assigned position at the time of the observation and ensuring adequate backup documentation is available to verify the activity being performed. Ohio Admin. Code 5101:9-7-20(K) indicates that the Children Services shall retain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. We noted two instances out of 25, or eight percent of the RMS hits tested did not agree to the Statewide Automated Child Welfare Information System (SACWIS) documentation, or there was no documentation in the SACWIS system provided to support the activities of the employee for the code charged. Failure to maintain support for these activities could cause incorrect charges to federal programs. We recommend Guernsey County Children Services provide a review to its employees of federal requirements and required documentation and develop a plan to reduce discrepancies between RMS and SACWIS. Officials’ Response: See Corrective Action Plan.