Finding Text
Criteria:
Eligibility- Individual
Material Weakness and Noncompliance
The Department as an eligible State has submitted to the Secretary of the U.S. Treasury a State Plan
that outlines the way the State intends to conduct the TANF program as requested by 42 U.S.C. Part
602 Section (a)(1)(A)(i). The State Plan shall set forth objective criteria for the delivery of benefits
and the determination of eligibility and for fair and equitable treatment, including an explanation of
how the State will provide opportunities for recipients who have been adversely affected to be heard
in a State administrative or appeal process as required by 42 U.S.C. Part 602 Section (a) (1) (B) (iii).
The Temporary Assistance for Needy Families Program State Plan of Operation for fiscal years
2018 through 2020 of the Government of Puerto Rico (the State Plan), Chapter IV-Application
Process, establishes financial and non-financial eligibility requirements for applications and
redeterminations; the assistance unit that will be considered for benefits and services; supportive
evidence of eligibility requirements; and other eligibility factors and criteria
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 fifteen (15) 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:
• (4) Verification of Valid ID.
• (7) Income Verification Form for audited period.
• (2) Information Verification Form.
• (1) Participant file was not available for our review.
The valid identification is an eligibility control established in the program's state plan to prove the
existence of participants.
The Income Verification Form is a document completed by the TSAF (evaluators) to determine if
the applicant's net income, for a given period, does not exceed the Maximum Monthly Income for
compliance with the 150°0 poverty threshold.
Information Verification Forms must be completed during initial and re-evaluation processes to track
any change on the participants' attributes (whether income or Non income attributes).
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 regarding 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