Finding 551128 (2024-004)

Material Weakness Repeat Finding
Requirement
EN
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 352056
Organization: County of Solano (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to retain required eligibility forms (CW2.1 and SAWS 2A SAR) for some applicants, leading to a material weakness in internal controls.
  • Impacted Requirements: Compliance with the 2024 OMB Compliance Supplement mandates proper documentation for eligibility determinations and redeterminations.
  • Recommended Follow-Up: Strengthen policies and procedures to ensure all necessary forms are obtained and retained to mitigate risks of noncompliance.

Finding Text

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our special tests and provisions testing, we noted three (3) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the Rights, Responsibilities, and Important Information (form SAWS 2A SAR) for support the applicants initial interview application. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. The County’s policies and procedures did not ensure that all SAWS 2A SAR forms were retained with signatures in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In three (3) out of 60 cases, we found that the County did not retain a copy of the CW2.1 to evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In one (1) out of 60 cases, we found that the County did not retain a copy of the SAWS 2A SAR to evidence the applicants’ rights and responsibilities. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-004. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Corrective Action Plan

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: CW 2.1: Solano County has policies and procedures as well as systematic processes set up to ensure the required collection and documentation of the applicant’s intent to cooperate with child support. It is Solano County’s policy that the Child Support Questionnaire (CW 2.1Q) and Notice and Agreement (CW2.1NA) be processed in accordance with regulations, which require workers to: • Conduct an interview either via telephone, or in-person with the applicant, print the forms, and document the County Use Section which requires worker’s signature and date. • Mail the forms to the applicant for a wet signature or collect the signature via electronic means. • Ensure the CW2.1 forms are received and complete. • Initiate the required case action(s) based upon information provided on the forms. Solano County has a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent this error in the future: • A post-Audit meeting will be held with all stakeholders to discuss the specific audit findings and action steps needed. • The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the applicable eligibility handbook with verbiage to emphasize the following: o The requirement to review and collect the information needed to complete the notice and agreement (form CW2.1) for child, spousal, and medical support from the applicant. o That the case be authorized according to program rules only after required forms are received by the county, reviewed to ensure that the case is updated with the correct information, documented in the case journal, and the form(s) scanned into the document imaging system. o Highlight these requirements when training this topic. • The CalWORKs Program Specialist will address the findings and requirements as follows: o Present at the Monthly Program Support Forum conducted with managers, supervisors, and lead workers. o Written guidance and reminder will be published in the Monthly Program Support Newsletter to all staff. o Present and discuss this requirement with lead workers at the Lead Worker Coordination Meeting, and with supervisors at the Division Coordination Meeting. • In addition to regular case reviews, focused case reviews will be added to review for completion of the Notice and Agreement for Child, Spousal, and Medical Support (form CW 2.1). SAWS 2A SAR: Solano County has policies and procedures as well as systematic processes set up to ensure the worker has reviewed the Rights and Responsibilities (SAWS 2A SAR) with the applicant/recipient and obtain their signature. It is Solano County’s policy that the SAWS 2A SAR be processed at application and redetermination which require workers to: • Conduct an interview either via telephone, or in-person with the applicant, print the form, and document the worker’s signature and date. • Mail the form to the applicant for a wet signature or collect the signature via electronic means. • Ensure the completed form is on file prior to authorizing benefits. Solano County has a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent this error in the future: • A post-Audit meeting will be held with all stakeholders to discuss the specific audit findings and action steps needed. • The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the applicable eligibility handbook with verbiage to emphasize the following: o That the case be authorized according to program rules only after the signed SAWS 2A SAR form is received by the county, documented in the case journal, and the form(s) scanned into the document imaging system. o Highlight these requirements when training this topic. • The CalWORKs Program Specialist will address the finding and requirement in the following ways: o Present at the Monthly Program Support Forum conducted with managers, supervisors, and lead workers. o Written guidance and reminder will be published in the Monthly Program Support Newsletter to all staff. o Present and discuss this requirement with lead workers at the Lead Worker Coordination Meeting, and with supervisors at the Division Coordination Meeting. • In addition to regular case reviews, focused case reviews will be added to review for completion of the Rights and Responsibilities (SAWS 2A SAR). Responsible Individual(s): Daniel Horel, Employment and Eligibility Services Administrator Thomas West, Employment and Eligibility Services Manager Diana Hernandez, Employment and Eligibility Services Manager Jennifer Stephenson, Employment and Eligibility Services Manager Anticipated Completion Date: May 31, 2025

Categories

Eligibility Special Tests & Provisions Material Weakness

Other Findings in this Audit

  • 551124 2024-002
    Material Weakness Repeat
  • 551125 2024-003
    Material Weakness Repeat
  • 551126 2024-002
    Material Weakness Repeat
  • 551127 2024-003
    Material Weakness Repeat
  • 551129 2024-005
    Material Weakness Repeat
  • 551130 2024-006
    Material Weakness
  • 551131 2024-007
    Material Weakness
  • 551132 2024-008
    Material Weakness
  • 551133 2024-009
    Material Weakness
  • 1127566 2024-002
    Material Weakness Repeat
  • 1127567 2024-003
    Material Weakness Repeat
  • 1127568 2024-002
    Material Weakness Repeat
  • 1127569 2024-003
    Material Weakness Repeat
  • 1127570 2024-004
    Material Weakness Repeat
  • 1127571 2024-005
    Material Weakness Repeat
  • 1127572 2024-006
    Material Weakness
  • 1127573 2024-007
    Material Weakness
  • 1127574 2024-008
    Material Weakness
  • 1127575 2024-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $34.64M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $26.74M
93.778 Medical Assistance Program $25.49M
93.563 Child Support Services $8.21M
93.658 Foster Care Title IV-E $8.04M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $6.78M
93.659 Adoption Assistance $6.42M
14.871 Section 8 Housing Choice Vouchers $3.35M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $3.34M
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $1.85M
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.73M
93.493 Congressional Directives $959,528
93.268 Immunization Cooperative Agreements $837,626
93.090 Guardianship Assistance $767,628
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $765,610
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $746,426
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $708,692
16.575 Crime Victim Assistance $635,975
20.205 Highway Planning and Construction $628,045
93.958 Block Grants for Community Mental Health Services $506,140
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $424,659
16.606 State Criminal Alien Assistance Program $394,927
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $362,314
93.958 Covid-19 Block Grants for Community Mental Health Services $362,153
93.667 Social Services Block Grant $356,384
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $333,754
93.994 Maternal and Child Health Services Block Grant to the States $323,782
93.069 Public Health Emergency Preparedness $302,111
20.616 National Priority Safety Programs $294,731
93.052 National Family Caregiver Support, Title Iii, Part E $294,264
93.044 Covid-19 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $289,012
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $269,383
93.053 Nutrition Services Incentive Program $266,373
93.526 Grants for Capital Development in Health Centers $255,823
93.556 Marylee Allen Promoting Safe and Stable Families Program $236,441
93.889 National Bioterrorism Hospital Preparedness Program $196,468
14.879 Mainstream Vouchers $187,605
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $187,186
97.042 Emergency Management Performance Grants $158,071
14.896 Family Self-Sufficiency Program $155,586
17.278 Wioa Dislocated Worker Formula Grants $147,462
93.645 Stephanie Tubbs Jones Child Welfare Services Program $143,203
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $128,700
93.940 Hiv Prevention Activities Health Department Based $125,372
20.106 Covid-19 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $115,934
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $104,751
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $92,833
97.012 Boating Safety Financial Assistance $85,878
59.037 Small Business Development Centers $69,625
93.747 Elder Abuse Prevention Interventions Program $66,066
17.258 Wioa Adult Program $62,160
10.025 Plant and Animal Disease, Pest Control, and Animal Care $61,139
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $57,750
93.959 Block Grants for Prevention and Treatment of Substance Abuse $55,000
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $53,578
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $50,750
93.590 Community-Based Child Abuse Prevention Grants $38,567
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $38,494
93.043 Covid-19 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $36,060
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $30,142
93.917 Hiv Care Formula Grants $25,166
93.959 Covid-19 Block Grants for Prevention and Treatment of Substance Abuse $23,521
16.738 Edward Byrne Memorial Justice Assistance Grant Program $21,673
17.259 Wioa Youth Activities $11,867
93.527 Covid-19 Grants for New and Expanded Services Under the Health Center Program $11,337
16.U02 Safe Streets Crime Incentive $10,544
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $10,284
93.042 Covid-19 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $6,145
16.U04 Domestic Cannabis Eradication Suppression Program $5,477
93.603 Adoption and Legal Guardianship Incentive Payments Program $4,191
16.U03 Domestic Cannabis Eradication Suppression Program $3,184
97.067 Homeland Security Grant Program $247