Finding No. 2022 015: Eligibility, Activities Allowed or Unallowed, Allowable Cost (Material Weakness) Federal Agency: U.S. Department of Health and Human Services AL Number and Title: 93.658 and COVID 19 ? 93.658 ? Foster Care ? Title IV E Award Number and Award Year: 2101HIFOST, 2201HIFOST Condition We selected a non statistical sample of 40 case files which approximated $32,000 in monthly benefit payments, out of a population of approximately 981 case files which approximated $4.89 million in total annual benefit payments, for testing and noted exceptions in 13 case files as follows: ? Three case files where the Police Protective Custody form or Voluntary Foster Custody Agreement was missing and therefore did not support whether the child was removed as part of a voluntary placement agreement or judicial determination. ? Three case files where the State, FBI, and/or child abuse and neglect clearances were missing. ? Seven case files where the ?difficulty of care? determination was missing and therefore did not support the assistance amount paid. ? Two case files where the ?Certificate of Approval? was missing and therefore did not support whether the prospective foster parents were licensed. Views of Responding Officials: The Department agrees with the finding and will implement corrective action. Corrective Action Taken or Planned: 1. Child Welfare Service (CWS) will make a note in each specific case record identified in this audit explaining the audit findings, and secure missing/incomplete eligibility documents for cases identified in the audit. 2. The identified errors and the related corrective action step above will be reviewed by CWS Administrators, staff supervisors, and Management Information Compliance Unit (MICU) within ninety days to ensure missing documentation has been secured and properly noted in record. ? Additionally, the MICU will complete a random Title IV-E Foster Custody payments audit review approximately six months later. i. MICU will share random audit findings with CWS Administrators. ii. CWS Administrators will take corrective action based on MICU audit findings. 3. CWS supervisors will ensure that line staff (especially those responsible for Licensing and Placements) are familiar with these policies and procedures and monitor through individual supervision meetings and work product review. ? Staff with errors identified in this audit, during individual supervision meetings or through work product review will: i. be given coaching/supervisory support to correctly complete documentation, ii. be required to participate in refresher training on Title IV-E Foster Custody, which is offered three times a year with participation documented by Staff Development Office. ? All staff who manage Title IV-E Foster Custody payments will review a quarter of their cases each month with their supervisor, during monthly supervision. i. Each month, a different quarter of their cases will be reviewed, always starting with the newest cases. ii. During this review between the supervisor and the staff, documentation in the case file, as well as Child Protective Services System (CPSS) coding and payments, will be examined for completeness and consistency. iii. Needed corrections will be made to the documents and/or CPSS, as identified in the monthly reviews. iv. If a supervisor notices consistent errors by a staff member in Title IV-E Foster Custody payments documentation, they shall refer the staff to the Staff Development Office for refresher training. v. The supervisor shall document which cases were reviewed each month. ? All licensing staff shall review a quarter of their cases every month with their supervisor, during monthly supervision. i. Each month, a different quarter of their cases will be reviewed, always starting with the newest cases. ii. During this review between the supervisor and the staff, documentation (including all background clearances) in the case file will be examined for timeliness and completeness. iii. Needed corrections will be made to the documents and/or new documents added, as identified in the monthly reviews. iv. If a supervisor notices consistent errors by a staff member in Title IV-E Foster Custody payments documentation, they shall refer the staff to the Staff Development Office for refresher training. v. The supervisor shall document which cases were reviewed each month. 4. At the next Management Leadership Team meeting, CWS Branch Administrators will share with staff the results of this audit, explaining the direct correlation between documentation (or lack thereof) and financial penalties to the State. ? Reminder conversations about this audit and the importance of following current policies and procedures will be held during CWS weekly huddles. 5. As CWS implements this corrective action plan and monitors the results, the action steps proposed in one through four may be modified based on input from CWS Administrators and/or focus/exploration groups with line staff who complete this documentation. Expected Completion Date: May 31, 2023, and On-going Responding Officials: Kisha C. Raby, Social Services Division Program Development Administrator, Elladine Olevao, Social Services Division Child Welfare Social Services Manager, and Carolina Anagaran, Social Services Division Administrative Officer