Finding Text
Criteria:
The Department is required to identify in its annual plan the population eligible for NAP benefits.
In testing the propriety of eligibility determinations and disbursements for NAP benefits, the auditor
shall apply the eligibility criteria established by the Department and identified in the annual plan (7
CFR section 285.3(b)(2)).
7 CFR Part 285 Section 3 Plan of Operation, states (b) The plan of operation shall include the
following information: (2) A description of the needy persons residing in the Commonwealth of
Puerto Rico and an assessment of the food and nutrition needs of these persons. The description and
assessment shall demonstrate that the Nutrition Assistance Program is directed toward the neediest
persons in the Commonwealth of Puerto Rico.
Condition:
We noted several files for participants of the referenced federal award were not complete to evaluate
properly and conclude participant/beneficiary was eligible, as required by the Department
procedures and federal law. As a result, we could not conclude participants reviewed were eligible
to receive benefits as required by the federal award.
Perspective — We selected a sample of forty (40) participant files as part of compliance testing
regarding eligibility, auditors noted several cases in which the following documentation was not
present in participants' files as follows:
• (6) Valid ID
• (7) Evidence of Residency
The ID verification of participants is the control established by the administration in its state plan to
confirm the existence of the participants receiving benefits.
Evidence of residency is a control placed by the administration in its state plan to confirm
participants' physical addresses to prevent participants from receiving benefits from two distinct
locations (states) or multiple participants receiving benefits from the same address without being
considered as a familiar unit.
Effect:
The Department may be qualifying participants who do not meet the eligibility requirements
established by federal regulations. This may ultimately result in sanctions, reduced funding, having
to return monies to the federal agency, or cancellation of grants.
Cause:
The Department is not adhering to the established internal control procedures and not adequately
documenting its evaluation and conclusion over the eligibility of participants.
Recommendation:
The Department must adhere to its existing internal control procedures to properly document
eligibility verification procedures performed and to ensure compliance with federal regulations and
the State Plan. All documents established by the Department to evaluate and conclude participants
are eligible, need to be obtained and evidenced in the participant's file.
The Department should also properly communicate eligibility verification procedures to employees
and provide a clear outline as to the tasks, responsibilities, and supervision and approval tasks for
each employee within the eligibility verification process.
In case, any document established for verification of eligibility is temporarily waived due to specific
reasons (natural disasters, pandemic, etc.) the Department should formally communicate the
provisions of the temporary waiver, obtain approval of the federal awarding agency, and formal
communication should be included in the participant's file.
Questioned Costs:
Could not be determined.
Management's Response:
Refer to Grantee's Corrective Action Plan.