Finding 957384 (2023-001)

Finding Reference: 2023-001 Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Adoption Assistance Assistance Listing Number: 93.659 Pass Through Entity: California Department of Social Services Grant Number: None Category of Finding: Eligibility Classification of Finding: Significant Deficiency in Internal Control over Compliance Criteria States are required to adopt and adhere to their own statutes and regulations for Adoption Assistance Program (AAP) implementation, consistent with the requirements of Title IV-E of the Social Security Act and the approved Title IV-E Plan. California Code of Regulations, Title 22, Division 2, section 35333 Determination of Amount and Duration of AAP Benefit for All Children states that “reassessment of the AAP benefit shall be required every two (2) years beginning from the date of a signed Adoption Assistance Program Agreement (AD 4320) between the agency and the adoptive parents.” CFR Title 75, section 75.303 Internal Controls requires the non-federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition The City’s Human Services Agency (Department) administers the program and oversees the assessments and continued reassessments of participant eligibility. We tested a statistically valid sample of 60 participants selected from a population of 1,087 receiving AAP benefits for the period of July 1, 2022 through June 30, 2023. Of the 60 cases tested, seven cases did not contain documentary evidence of supervisory review of reassessments performed by eligibility caseworkers. Cause of Condition The Department’s policy is for eligibility supervisors to review the assessments and reassessments performed by the eligibility caseworkers for the Adoptions Assistance program. Checklists are maintained to document the necessary steps and files to be retained for each reassessment performed. However, supervisor reviews were not consistently performed on all reassessments and the checklists used by the caseworkers were not consistently applied. This was primarily due to program personnel having limited accessibility to physical files during the restrictions of the COVID-19 pandemic. Effect There is a potential for not identifying ineligible participants in a timely manner. Questioned Costs There are no questioned costs. Program participants are considered to be eligible for benefits once they are initially determined to be eligible through the point when they reach age 18, the adoptive parents are no longer legally responsible for the support of the child or the adoptive parents are no longer providing support to the child. None of the seven cases met one of these triggering events. Identification of Repeat Findings This is not a repeat finding from the prior year audit. Recommendation We recommend that the Human Services Agency revisit and implement a more robust review process for eligibility reassessment reviews and ensure that documentation of reviews is consistently maintained. View of Responsible Officials and Planned Corrective Action See separately prepared Corrective Action Plan.