Finding 571928 (2024-001)

Significant Deficiency
Requirement
ABE
Questioned Costs
-
Year
2024
Accepted
2025-07-25
Audit: 363015
Organization: Jefferson County Government (CO)

AI Summary

  • Core Issue: Missing signed agreements for maintenance payments and late 90-day reviews increase the risk of errors in foster care payments.
  • Impacted Requirements: Compliance with Title IV-E payment agreements and timely Family Services Plan reviews as per federal and state regulations.
  • Recommended Follow-Up: Strengthen internal controls for eligibility and payments, and report system limitations to the state for better notification processes.

Finding Text

Finding: Allowable Activities & Allowable Costs and Eligibility Federal Assistance Listing Number 93.658 – Foster Care-Title IV-E Department of Health and Human Services, Passed-Through Colorado Department of Human Services Award Number – None Provided; Award Year 2024 Criteria or Specific Requirement: Funds may be expended for foster care maintenance payments on behalf of eligible children, in accordance with the Title IV-E agency’s foster care maintenance payment rate schedule and in accordance with 45 CFR section 1356.21, to individuals serving as foster family homes, to childcare institutions, or public/private child-placement or child-care agencies. In accordance with Code of Colorado Regulations (CCR) section 7.302.2, for each child, Jefferson County Human Services (JCHS) must have an agreement with the provider which details the daily maintenance payments. JCHS agreement to purchases services must be signed by the provider and JCHS. Additionally, in accordance with CCR section 7.301.3, the Family Services Plan shall be reviewed in conference with the caseworker and supervisor every 90 calendar days. Condition: During our testing, we noted the following:  Two instances out of 40 where there was no signed agreement in place to support revised maintenance payments following a child’s 9th birthday. The correct maintenance amount was paid to the provider in accordance with the state of Colorado rates published in IM-CW–2024-0028 and IM-CW-2023-0021.  One instance out of 40 where the required 90-day review was not completed on time. The review was conducted 15 days late. Questioned Costs: None. Context: We tested 40 foster care placements that received Title IV-E assistance for the year ended December 31, 2024, and noted the issues described above. The tested sample represented approximately $102,000 in benefits issued. The total population consisted of approximately $1.8 million in benefits issued to approximately 700 individuals. A non-statistical sampling methodology was used to select the sample. Effect: The absence of appropriate controls related to the above requirements increases the risk of incorrect maintenance payments or the provision of inappropriate services to clients. Cause: The state's foster care system did not automatically generate a notice that a new agreement to purchase services was needed based on the child's birthday. Additionally, JCHS lacks an effective control mechanism to proactively identify when a 90-day review is approaching or overdue. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations and maintenance payments. This includes evaluating the need for additional backup controls when relying on the state’s foster care system. Additionally, we recommend that JCHS submit help desk tickets to the state to report the system limitation regarding notifications for agreement updates based on a child's birthday. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Corrective Action Plan

Finding: Allowable Activities & Allowable Costs and Eligibility (Reference Number: 2024-001) Criteria or Specific Requirement: Funds may be expended for foster care maintenance payments on behalf of eligible children, in accordance with the Title IV-E agency’s foster care maintenance payment rate schedule and in accordance with 45 CFR section 1356.21, to individuals serving as foster family homes, to childcare institutions, or public/private child-placement or child-care agencies. In accordance with Code of Colorado Regulations (CCR) section 7.302.2, for each child, Jefferson County Human Services (JCHS) must have an agreement with the provider which details the daily maintenance payments. JCHS agreement to purchase services must be signed by the provider and JCHS. Additionally, in accordance with CCR section 7.301.3, the Family Services Plan shall be reviewed in conference with the caseworker and supervisor every 90 calendar days. Condition: • Two instances out of 40 where there was no signed agreement in place to support revised maintenance payments following a child’s 9th birthday. The correct maintenance amount was paid to the provider in accordance with the State of Colorado rates published in IM-CW–2024-0028 and IM-CW-2023-0021. • One instance out of 40 where the required 90-day review was not completed on time. The review was conducted 15 days late. Cause: The state's Foster Care system did not automatically generate a notice that a new agreement to purchase services was needed based on the child's birthday. Additionally, JCHS lacks an effective control mechanism to proactively identify when a 90-day review is approaching or overdue. Corrective Action Plan: We agree with the finding. The Integrated Case Management System (ICM) is designed to generate an email notification to Collaborative Foster Care Program (CFCP) staff when a child turns 9 or 14 years of age while in foster care. This email notification instructs CFCP staff to generate a new Child Specific Addendum (SS23-B) due to the increase of the child maintenance rate. This email instructs and standard procedure requires CFCP staff to verify the child maintenance rate in Trails after an SS23-B is generated. The IT Systems Support Team responsible for the maintenance of ICM determined that ICM has failed to notify CFCP staff when a child turned 9 or 14 years of age while in foster care: • The IT Systems Support Team responsible for the maintenance of ICM has been asked to ensure that ICM is generating an email notification when a child turns 9 or 14 years of age while in foster care. • While this issue is being addressed in ICM, the CFCP requested a report that included the birthdays for all children in foster care. CFCP staff have generated new Child Specific Addendums (SS23-B) for children that have turned 9 or 14 years old while in foster care. CFCP staff will utilize this report to generate new Child Specific Addendums for future birthdays. • After a new Child Specific Addendum is generated, staff will verify the child maintenance rate in Trails. • The CFCP has determined that it can no longer rely on ICM and has decided to migrate its functionality over to the ancillary system supported by Jefferson County known as the Caseworker Application Timesaver (CAT). With this migration, the email notifications will resume so that CFCP staff are properly notified of the need to generate the new SS23-B and verify the child maintenance rate. • Migration is scheduled to occur on Friday, June 20, 2025. • On Monday, June 23, 2025, the CFCP will meet with the Jefferson County Application Program Analyst to ensure the migration was successful. • Additionally, the CFCP and the Jefferson County Application Program Analyst have scheduled a second meeting for July 9, 2025, to ensure the successful migration from ICM to CAT. • To ensure 90-Day Reviews are completed timely, the Division of Children, Youth, Families, and Adult Protection (CYFAP) will continue to utilize the 90-Day Review compliance feature of CAT. Additionally, CYFAP leadership will emphasize this requirement with supervisors and casework staff and ensure their compliance. Person(s) Responsible for Implementation: Barb Weinstein, Director, Division of Children, Youth, Families and Adult Protection Implementation Date: July 1, 2025

Categories

Procurement, Suspension & Debarment Student Financial Aid Allowable Costs / Cost Principles Eligibility Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1148370 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $8.63M
93.778 Medical Assistance Program $7.90M
93.575 Child Care and Development Block Grant $6.80M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $6.10M
93.658 Foster Care Title IV-E $4.93M
93.600 Head Start $4.51M
93.563 Child Support Services $4.28M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $4.24M
93.576 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $3.27M
93.659 Adoption Assistance $2.43M
14.239 Home Investment Partnerships Program $1.92M
93.667 Social Services Block Grant $1.79M
16.576 Crime Victim Compensation $1.65M
21.023 Emergency Rental Assistance Program $1.65M
20.106 Airport Improvement Program $1.59M
17.278 Wioa Dislocated Worker Formula Grants $1.16M
17.207 Employment Service/wagner-Peyser Funded Activities $1.13M
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.03M
93.268 Immunization Cooperative Agreements $924,663
17.259 Wioa Youth Activities $887,938
93.471 Title IV-E Kinship Navigator Program $673,530
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $597,743
16.575 Crime Victim Assistance $596,594
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $554,665
93.069 Public Health Emergency Preparedness $526,523
14.231 Emergency Solutions Grant Program $449,310
93.568 Low-Income Home Energy Assistance $449,290
17.258 Wioa Adult Program $447,717
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $425,676
17.225 Unemployment Insurance $393,097
93.569 Community Services Block Grant $376,692
16.738 Edward Byrne Memorial Justice Assistance Grant Program $341,562
16.741 Dna Backlog Reduction Program $336,539
93.472 Title IV-E Prevention Program $331,235
93.994 Maternal and Child Health Services Block Grant to the States $268,623
93.788 Opioid Str $248,787
95.001 High Intensity Drug Trafficking Areas Program $247,754
90.404 Hava Election Security Grants $246,326
16.588 Violence Against Women Formula Grants $228,015
10.558 Child and Adult Care Food Program $224,092
93.217 Family Planning Services $221,544
93.645 Stephanie Tubbs Jones Child Welfare Services Program $219,855
16.606 State Criminal Alien Assistance Program $187,556
93.136 Injury Prevention and Control Research and State and Community Based Programs $172,663
10.723 Community Project Funds - Congressionally Directed Spending $162,319
15.226 Payments in Lieu of Taxes $146,777
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $133,207
17.285 Registered Apprenticeship $102,350
15.437 Minerals Leasing Act $99,430
97.067 Homeland Security Grant Program $98,970
10.551 Supplemental Nutrition Assistance Program $82,562
97.042 Emergency Management Performance Grants $80,078
17.270 Reentry Employment Opportunities $73,678
20.600 State and Community Highway Safety $64,074
17.268 H-1b Job Training Grants $58,317
93.090 Guardianship Assistance $50,386
16.922 Equitable Sharing Program $50,251
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $44,683
66.605 Performance Partnership Grants $38,779
17.801 Jobs for Veterans State Grants $37,884
10.665 Schools and Roads - Grants to States $34,268
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $30,308
93.317 Emerging Infections Programs $28,379
93.092 Affordable Care Act (aca) Personal Responsibility Education Program $25,693
93.991 Preventive Health and Health Services Block Grant $25,546
20.616 National Priority Safety Programs $17,271
21.016 Equitable Sharing Program $15,841
14.218 Community Development Block Grants/entitlement Grants $11,399
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $8,278
97.052 Emergency Operations Center $7,493
93.556 Marylee Allen Promoting Safe and Stable Families Program $3,102
93.747 Elder Abuse Prevention Interventions Program $-7,470