Finding 525650 (2024-002)

Finding 2024-02: Material Noncompliance/Material Weakness in Internal Control Criteria: Uniform Guidance 2 CFR § 200.303 requires the non-Federal entity to “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.” Reasonable assurance includes the County documenting a key control was implemented. Condition: The County has not implemented a formal process or internal policy for performing 2nd party reviews to verify the income verification and eligibility determinations made by County staff. Questioned Costs: No questioned costs. Context: The 2nd party review process is the key internal control over the accuracy of FNS/SNAP case income verification and eligibility determinations made by County staff. County staff noted that they follow the Federal policy regarding 2nd party review over FNS, which requires 2nd party reviews on all households with five of more members and try to perform others reviews as time allows, but that documentation of these reviews is not maintained. There was no documentation available for us to review to verify that any 2nd party reviews had been performed. Cause: The County does not have a formal policy requiring 2nd party reviews be performed or a process to document the 2nd party reviews that are performed. Effect: The current 2nd party review process does not function as an effective internal control over compliance. Identification of repeat finding: This is not a repeat finding. Recommendation: We recommend the implementation of a formal and documented 2nd party review process to include an appropriate number of reviews given the volume of applications processed for a given time period. These 2nd party reviews that are performed should be selected from the entire population of cases, not just those with 5 or more household members. Views of Responsible Officials and Planned Corrective Actions: The County agrees with this finding and is taking coordinated effort and action. Refer to corrective action plan on subsequent page 15.