Finding Text
Federal Program: Area Agency on Aging (AAA) – Various ALNs under the Older Americans Act (e.g., 93.044, 93.045, 93.052)
Compliance Requirement: Eligibility and Documentation Requirements
Type of Finding: Internal Control Deficiency
Condition:
During our review of client intake documentation for services provided under the AAA programs, we identified multiple instances in which intake forms were not signed by the assigned case worker. While client demographic information and signatures were present, the absence of case worker signatures indicates that formal review and approval of client eligibility and service initiation was incomplete in accordance with established procedures.
Criteria:
Per Older Americans Act program guidance, eligibility determinations and service documentation must be reviewed and authorized by qualified staff. Standard internal control practices further require that intake forms be signed and dated by both the client and the case worker to provide audit evidence of eligibility assessment and case manager oversight. The case worker’s signature serves as confirmation that intake information was reviewed for accuracy, eligibility criteria were met, and services were appropriately initiated.
Cause:
The condition appears to result from inconsistent application of intake protocols and a lack of secondary review to ensure completion of required documentation fields, including the case worker’s signature.
Effect:
Incomplete intake documentation compromises the integrity of the client eligibility process and increases the risk of noncompliance with federal program standards. It may also impair the agency’s ability to demonstrate proper eligibility determination and oversight in the event of federal or state monitoring.
Recommendation:
We recommend that STDC strengthen controls over the intake and eligibility documentation process by:
• Reinforcing existing policies that require case worker signatures on all intake forms;
• Implementing a secondary review or quality assurance step prior to initiating services to verify that all required documentation, including signatures, is present;
• Providing targeted training to intake and case management staff on documentation standards and accountability requirements under Older Americans Act programs.
Questioned Costs: None