Finding Text
2023-006 Supporting Documents for Eligibility Requirements
Program Name: State Opioid Response
Federal Assistance
Listing No.: 93.788
Federal Agency: Department of Health and Human Services
Federal Award Identification: Unknown
Pass-Through Entity Number: Unknown
Applicable Pass-Through Entity: Ohio Department of Mental Health and Addiction Services and Cuyahoga County, Ohio
Type of Finding: Significant Deficiency
Compliance Requirement: Eligibility
Criteria: According to Section 200.303 of the Uniform Guidance, a nonfederal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Point of Freedom must document their policies and procedures in determining eligibility and must have controls in place to ensure compliance with their policies and procedures and prevent fraud.
Condition: The organization currently lacks valid identification documents for some residents, many of whom are homeless.
Cause of Condition: The absence of proper identification documentation is primarily due to the residents' homeless status, which complicates the collection and maintenance of such documents.
Effect: Without valid identification documents, the organization may face challenges in meeting eligibility requirements and ensuring compliance with documentation standards. This could potentially affect the program's effectiveness and the residents' access to necessary services.
Questioned Cost: Not Quantifiable
Context: We reviewed documentation for 5 participants and found that 2 of them do not have valid identification documents. This issue is particularly prevalent among homeless residents.
Recommendation: We recommend that the organization implements a systematic approach to documenting residents' identification, including those who are homeless. Additionally, the organization should consult with the program manager to establish guidelines and procedures for effectively documenting identification in cases where traditional documentation is challenging to obtain.
Views of Responsible Officials: During September 2024, POF updated its Housing Procedures Manual in compliance with Section 200.303 of Uniform Guidance and Ohio Recovery House Regulations. This document now more fully addresses, among other things, eligibility and required minimum documentation standards. POF has already begun to build individual client files to retain and periodically update these required supporting documents for all Its affected residential clients.