Finding Text
Criteria: Per Uniform Guidance (2 CFR Part 200), entities administering
federal programs must maintain appropriate documentation to support
participant eligibility and ensure compliance with federal program
requirements. Additionally, per the program’s grant agreement and eligibility
requirements, the Organization must obtain and retain documentation
verifying that enrollees meet the required eligibility criteria before providing
program benefits.
Condition: During our testing of participant eligibility, we reviewed 60
participant files and found that 1 file lacked sufficient documentation to verify
eligibility. Specifically, the missing documentation included, the participant
was enrolled over the phone and the formal application and supporting
documentation supporting eligibility was not maintained by the program.
Without this documentation, the Organization cannot demonstrate that this
participant met the eligibility requirements for program benefits.
Cause: The Organization does not have a robust process to ensure that all
required eligibility documentation is consistently obtained, reviewed, and
retained.
Effect: Failure to maintain complete eligibility documentation increases the risk
of ineligible individuals receiving program benefits, which could result in
noncompliance with grant requirements and potential disallowed costs.
Questioned Costs: None.
Recommendation: We recommend that the entity implement and enforce a
standardized eligibility verification process, including:
Developing a checklist to ensure all required eligibility documents are
obtained before approving enrollment.
Providing training to staff on eligibility documentation requirements.
Conducting periodic internal reviews of participant files to ensure
compliance with program guidelines.
The Organization’s Response: Management acknowledges the findings from
the audit.