Finding Text
Criteria:
The Department is required to identity 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.
We noted several files for participants of the referenced federal award were not complete to evaluate properly and conclude participantlbeneficiary 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' tiles as follows:
• (2) Verification of valid ID
• (2) Evidence of residence
• (3) Release of information form
• (2) USA Citizenship or Verification of Alien Status form
• (2) No copy of Social Security ID or SAID.' verification form of participants
• (2) Resource Verification Form ($5k-$15k)
• (2) Determination form
• (2) Notification Advice form
The above documentation is required as part of the eligibility controls established in the program's state plan to prove the existence of participants.
Effect:
The Department may be qualifying participants who do not meet the eligibility requirements established by federal regulations. T his 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 \kith 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_