Finding 501221 (2023-003)

Finding: 45 CFR Section 261 .63 requires the Alabama Department of Human Resources to submit a Work Verification Plan to the U.S. Department of Health and Human Services (HHS) for approval. The Alabama Department of Human Resources must comply with its approved Work Verification Plan to ensure accuracy in reporting work activities by work eligible individuals on the Temporary Assistance for Needy Families (TANF) Data Report. Data for work participation activities are used in calculating work participation rates. During our testing of 25 TANF cases, we found two cases in which the hours reported for an individual participating in a work activity were inaccurate. The Department of Human Resources failed to ensure accuracy of data for work participation activities which may result in an inaccurate work participation rate. This is a significant deficiency in internal controls. The Department of Human Resources did not have adequate procedures in place to ensure that the information included on the TANF Data Report is accurate. Recommendation: The Department of Human Resources should establish and maintain effective internal controls to ensure accuracy in reporting work activities by work-eligible individuals on the TANF Data Report. Response/Views: We disagree. The finding statement declares that the Department of Human Resources failed to ensure accuracy of data for work participation activities which may result in an inaccurate work participation rate. This is a significant deficiency in internal controls. The Department of Human Resources did not have adequate procedures in place to ensure that the information included on the TANF Data Report is accurate. We do agree with the findings of two cases "in which the hours reported for an individual participating in a work activity were inaccurate." We agree that the 2 of the 25 cases selected had the incorrect frequency for the number of employment hours entered which could potentially affect the work participation rate for Alabama. Corrective Action Planned: The two cases which involved an error in the frequency of the hours reported appear to be isolated and inadvertent in nature. Our policy requires verification and calculation of employment hours at the beginning of employment and reverification and calculation of employment hours in the fifth month of employment. Based on our JOBS policy, your review of 25 cases, potentially represents up to 200 calculations and your findings indicate only 2 calculation errors. Furthermore, our research indicates that the errors in the two cases addressed in your findings did not have an affect on the State's overall Work Participation Rate. Additionally, we believe our supervisory reviews as well as a percentage of record rereviews remain the best way to monitor accuracy of information entered in our system while basic and refresher training remains the course of prevention for information prior to entry into the system. Basic training for each new employee involves two weeks of intense, in person, interactive training. Refresher training or one to one support is provided as needed or requested by county staff. The official policy and automation helpdesk are staffed by specialists, who responds to questions daily. County consultants also perform re-reviews of the county's reviews and provide guidance as observed or requested. The stated purpose of these processes is to ensure systematic review of the work done in the family assistance program; to identify worker problems; to identify error trends and concentrations; and to monitor program performance. At the county level information from that process can be used for worker performance assessment, local corrective action, to train new workers, to identify areas of strengths and weaknesses of staff. At the State level the process provides information to monitor program performance to include identifying problems and error trends by county, region and statewide. Analysis of this data provides a way to determine training needs and to evaluate performance standards and the impact of program changes. The Division case record re-review process of the work of the supervisor provides yet another level of oversight to address the issues. Resulting corrective action from these reviews both at the County and State Office level can include additional individual worker or general staff training, program clarifications, as well as attention to the specific cases identified. Longstanding practice of such activity and experience tells us the process does prevent, detect, and correct errors. These errors have been discussed with the county worker and supervisor for case corrective action. Finally, DHR is in the final stages of development of a new TANF and JOBS system and we have requested that the hours of participation field require a question regarding the frequency of hours listed. Anticipated Completion Date: December 31, 2024. Contact Person(s): Fannie Ashley or Tessa Mitchell