HomeMy WebLinkAbout20100882.tiff STATE OF COLORADO
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Colorado Department of Human Services *raT6*
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EMPLOYMENT AND REGULATORY AFFAIRS Bill Ritter,Jr.
Jenise May,Deputy Executive Director Governor
AUDIT DIVISION Karen L.Beye
4126 South Knox Court Executive Director
Denver,Colorado 80236
Phone 303-866-7333
TDD 303-866-7105
FAX 303-866-7332
www.cdha.slate.co.us
Charissa M.Hammer,CPA,CFE
Director
April 22, 2010
Ms. Judy Griego, Director
Weld County Department of Social Services
PO Box A
Greeley, CO 80631
Dear Director Griego:
Thank you for your response to our County TANF Contract audit and for providing additional
documentation and information as requested. The audit was limited to the specific areas covered by our
request on September 14, 2009. At a later time, the Audit Division or other auditors may analyze other
expenditures that could result in additional questions or requests for information.
In 2008, the Colorado General Assembly passed Senate Bill 177 to comply with changes in Federal Law
governing the TANF program, as well as require that a county remit to the Colorado Long-term Works
Reserve any unspent TANF reserves in excess of a specified percentage of the county's TANF block
grant for a given fiscal year, starting in State Fiscal Year 2009. The average county reserve balance
going into State Fiscal Year 2009 was $1.4 million, with about one-third of the counties having reserves
in excess of$1.0 million. The Audit Division's Department-wide Risk Assessment for Fiscal Year 2010,
as well as a dramatic 39 percent increase in overall TANF expenditures between 2008 and 2009,
precipitated the decision to perform this audit. Auditing county expenditures is a routine way to comply
with our Federally mandated sub-recipient monitoring requirements. TANF expenditures, primarily
those incurred through various types of contracts, were the focus of this audit; basic cash assistance,
cash diversions, some supportive services, and personnel related costs were excluded from this audit.
The Audit Division used a combination of data, interview material, and best practices to perform an
evaluation of TANF contracts, memorandums of understanding, and related expenditures, in order to
determine whether the sampled expenditures were reasonable, allowable, and properly documented.
Our Mission is to Design and Deliver Quality Human Services that Improve the Safety and Independence of the Peor 2010-0882
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Ms. Judy Griego
April 22, 2010
Page 2
In addition, the Audit Division reviewed a random sample of 52 expenditures selected from CFMS
related to achieving the TANF purposes to perform analysis.
This letter contains information on four expenditures selected in the random sample portion of the audit.
After examining the information you provided and interviewing various staff involved in the process,
the following compliance issues were noted resulting in $769 in questioned costs. As seen in the
attached "corrective action template," factual corrections to this letter, if any, are due by May 14, 2010
and your Corrective Action Plan is due by June 8, 2010.
The auditors interviewed management and related staff regarding the sampled expenditures, and
reviewed the supporting documentation for the expenditures. The Audit Division reviewed the
following expenditures for your County:
A. I869.4195.65791 $768.95 paid to TIGHT program (reported in CFMS Oct09)
The following compliance issues result in questioned costs:
1. The selected expenditure was a reimbursement of clothing expenses for the youth participating in
the TIGHT program. TIGHT stands for Teamwork, Innovation, Growth, Hope, and Training,
which is a youth program for ages 13-17 that provides a safe environment while providing
educational and basic life skills components. TANF funds the direct services component of the
TIGHT program, while Child Welfare Core Services funds the personnel component.
Reportedly, the youth can either be living at the home or in a foster or group home to be eligible
for the TIGHT program. In order to be considered eligible under TANF requirements the
dependent child must be living in the home of the parent/caretaker relative within the 5`h degree
of kinship.
Agency Letter TCW 08-06-I Fiscal/Contracting Issues Regarding the Colorado Works Program
explains that, with the exception of services that are strictly for Purposes 3 or 4 and delivered to
the broad community via segregated Federal funds, all TANF expenditures must be
proportionate to the level of TANF participation. The Agency Letter further states that costs
should be distributed appropriately among any and all programs (Federal and State) in which
there is a direct benefit from that cost. In other words, each program must bear its fair share of
the costs. For example, if 60 of 100 individuals receiving services from a program are TANF
eligible, then TANF could fund up to 60 percent of the contract amount and the other benefiting
programs or county department funds would pay the remainder. The contractor must maintain
clear documentation to support the TANF purpose served and the individuals' eligibility.
Applications are not necessary for TANF services delivered to the broad community, but the
contractor must be able to approximate with reasonable certainty the number of TANF-eligible
individuals served, such as through a survey or a statistically significant sample of individuals
who received the service. The survey or sample must ascertain basic eligibility information,
including lawful presence, status of dependent children living in the home, and household gross
income (again, unless the contract is for community-wide services under Purposes 3 or 4 and
funded with segregated Federal funds). Further, OMB Circular A-87 Cost Principles for State,
Local, and Indian Tribal Governments states that any cost allocable to a particular Federal award
or cost objective under the principles provided for in this circular may not be charged to other
Ms. Ruth Wallace-Porter
April22, 2010
Page 3
Federal awards to overcome fund deficiencies, to avoid restrictions imposed by law or terms of
the Federal awards, or for other reasons.
Agency Letter TCW 08-06-I Fiscal/Contracting Issues Regarding the Colorado Works Program
states that when using TANF finds, the county department's two primary concerns should be to
ensure that the service is being provided to a TANF-eligible individual or family, and to tie the
expenditure to one of the four purposes of the Colorado Works Program, as outlined in Section
26-2-705, C.R.S. TANF block grant funds may pay for contractual services, as long as the
contractor can verify that finds were used to serve TANF-eligible individuals for TANF-eligible
purposes. Applications are not necessary for TANF services, but the contractor must be able to
approximate with reasonable certainty the number of TANF-eligible individuals served, such as
through a survey or a statistically significant sample of individuals who received the service.
The survey or sample must ascertain basic eligibility information, including lawful presence,
status of dependent children living in the home, and household gross income.
The Audit Division cannot determine if the clothing items that were purchased supported only
the TANF eligible youth. As a result, the Audit Division calculated $769 in questioned costs for
State Fiscal Year 2009 due to ineligible participants participating in the TIGHT program. This
amount can be mitigated to some degree if county department staff can document a method to
support the percentage of TANF eligible participants.
The following compliance issues do NOT result in questioned costs:
2. The expenditure to purchase clothing items for the TIGHT program was coded to program 1869
for transportation services. However, the Audit Division recommends that this type of expense
should have been coded to program 1863 for life skills services, to more closely align with the
purpose of this expenditure.
According to Staff Manual Volume 5 — Finance and Accounting (Executive Director) Rules (11
CCR 2508-1) Section 5.373 Correct Coding of Information, county departments of social/human
services must correctly code all information reported to the Colorado Department of Human
Services. Specifically in relation to an expenditure of funds from Colorado Works allocations,
Agency Letter TCW 08-06-I Fiscal/Contracting Issues Regarding the Colorado Works Program
contains the valid Colorado Works account code combinations necessary to enter the various
types of contracts into CFMS.
B. 1850.4210.64220 $10.00 paid to Multidisciplinary Youth Assessment Team (MYAT) (reported
in CFMS Dec09)
The selected expenditure was a reimbursement of a food expense incurred by a MYAT counselor. The
documentation provided included the reimbursement request for the MYAT counselor and a copy of a
receipt from Chicago Connection. The expenditure is an appropriate TANF expense and was
sufficiently documented; therefore the Audit Division found no compliance issues or questioned costs.
Our Mission is to Design and Deliver Quality Human Services that Improve the Safety and Independence of the People of Colorado
Ms. Judy Griego
April 22, 2010
Page 4
C. I400.4271.65791 $125.00 paid to Kiddieland Learning Center(reported in CFMS Oct09)
The selected expenditure paid for the summer camp activity fee for a TANF eligible child at the
Kiddieland Learning Center. The expenditure supported the TANF summer youth program, which is a
program designed to provide TANF eligible families with activities for their children to participate in
during the summer months in order to relieve boredom, reduce the incidence of harmful behavior, and
provide respite for parents and foster parents. The expenditure is an appropriate TANF expense and was
sufficiently documented; therefore the Audit Division found no compliance issues or questioned costs.
D. I400.4271.65791 $160.00 paid to MYAT Star Group (reported in CFMS Dec09)
The selected expenditure was a payment to Garcia Family Counseling for services provided through the
STAR group program on 11/5/08, 11/12/08, 11/19/08 and 11/26/08. STAR (Strategies That Are
Realistic), is a program that adds values-based knowledge to the lives of Weld County Youth. The
group aids youth in developing appropriate social, personal health, and academic skills. Its goal is to
help youth develop more productive and healthy lifestyles. The expenditure is an appropriate TANF
expense and was sufficiently documented; therefore, the Audit Division found no compliance issues or
questioned costs.
The above compliance issues will result in an audit adjustment of$769 by the end of State Fiscal Year
2010, as outlined in the attachment to this letter.
Because of many variables, including State and County budget constraints, the Department is working
diligently to reach a fair solution for all parties involved. While the Department is only taking back the
above adjustment, this letter will also serve as a disclaimer that if Federal or State governments audit
this area in the future and assess additional sanctions, these will be passed on to the county in question.
The Department will follow normal corrective action procedures, as specified in Staff Manual Volume 5
— Finance and Accounting (Executive Director) Rules (11 CCR 2508-1) Section 5.730 Audits by the
Colorado Department of Human Services and outlined in the attachment to this letter.
You may contact me at (303) 866-7324 if you have questions about our findings. Thank you for your
assistance throughout this audit.
Sii1n`cerely,, ^y/
Charissa Hammer, CPA, CFE
CDHS Audit Division Director
Enclosures
cc: Karen L. Beye, CDHS Executive Director
Leonard Bottorff, Fiscal and Budgeting Manager, Weld County Department of Social Services
Bill Hanna, CDHS Deputy Executive Director Colorado Works
Ms. Judy Griego
April 22, 2010
Page 5
Jenise May, CDHS Deputy Executive Director Employment & Regulatory Affairs
Dick Taylor, CDHS Controller
Weld County Board of Commissioners
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STATE OF COLORADO
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Colorado Department of Human Services *1876/
people who help people
EMPLOYMENT AND REGULATORY AFFAIRS Bill Ritter,Jr.
Jenise May,Deputy Executive Director Governor
AUDIT DIVISION Karen L.Beye
4126 South Knox Court Executive Director
Denver,Colorado 80236 •
Phone 303-866-7333
TDD 303-866-7105
FAX 303-866-7332 _.
www.cdhs.state.co-us .. .
Charissa M.Hammer,CPA,CFE
Director
•
•
To: Ms.Judy Griego,Director •
Weld County Department of Social Services
From: Charissa Hammer,CPA,CFE
CDHS Audit Division Director
Date: April 22,2010
Subject: County TANF Contracts, Memorandums of Understanding, and Other Expenditures Related to
Achieving TANF Purposes in State Fiscal Year 2009
Please review and, if necessary,respond to the(X)statements only.
1. ( ) Attached is a copy of the letter to the Director of Weld County Department of Social Services' County TANF
Contract audit conducted for your department,reflecting non-compliance issues with State rules and regulations.
2. ( ) Submit factual corrections to the preliminary report to me by: May 14,2010
3. ( ) If no factual corrections are necessary,please submit your Corrective Action Plan to me by:June 8,2010
4. ( ) This is the request for the above mentioned Corrective Action Plan,please submit to me by:
5. ( ) Your request for an extension of time has been granted,please submit your Corrective Action Plan to me by:
6. ( ) Your Corrective Action Plan for the above mentioned review has been accepted by the Audit Divsion.
7. ( ) Your Corrective Action Plan has not been accepted by the Audit Division,please respond to me by:
8. ( ) All non-compliance issues have been brought into compliance,bringing closure to this review.
If you have any questions regarding any of the above checked statements,please contact Charissa Hammer(303)866-7324.
Thank you for your cooperation in all areas concerning this review.
Our Mission is to Design and Deliver Quality Human Services that Improve the Safety and Independence of the People of Colorado
5.732 Corrective Action Process for Financial Compliance Reviews Performed by the Audit Division
5.732.1 Copy to County Director[Rev.eff.5/1/04]
The Colorado Department of Human Services,Audit Division,will mail one copy of the preliminary Financial Compliance Review report
to the County Director.
5.732.2 Deadline for Factual Corrections[Rev.eff.5/1/04]
The county department of social/human services will have 15 working days from the date of mailing to submit any factual corrections to
the Financial Compliance Review report to the Colorado Department of Human Services,Audit Division,4126 S.Knox Court,Denver,CO
80236. If no factual corrections are to be submitted,then the county department of social/human services shall have 30 working days from
the date of mailing to submit a corrective action plan to the Audit Division.
5.732.3 Corrective Action Plan[Rev.eff.5/1/04]
The corrective action plan submitted by the county department of social/human service shall include a:
A.Written Corrective Action Plan
Description,in writing,on how each non-compliance issue has been corrected;or
B.Information in the Corrective Action Plan
Plan, in writing,by which each non-compliance issue will be corrected. Such a plan must contain the following information for each non-
compliance issue:
1. Identify the non-compliance issue,
2.List the specific action(s)to be taken to correct the non-compliance,and
3.List the specific time frames for completion of each specific action.
5.732.4 Technical Assistance[Rev.eff.5/1/04]
The county department of social/human services may request technical assistance from the State in developing the corrective action plan.
This request must occur within the 30-day period.
5.732.5 Extension of Time[Rev.eff.5/1/04]
If the county department of social/human services needs additional time to develop a Corrective Action Plan, the county director must
submit a request in writing, to the Colorado Department of Human Services, Audit Division, 4126 S. Knox Court, Denver, CO 80236
specifying the new timeframe and providing an explanation for the extension request.
A.Review of Extension Request
The Colorado Department of Human Services, Audit Division, will review the request for time extension within five working days and
respond to the county director.
B.Acceptor Reject the Corrective Action Plan
Within 20 working days of receipt of the Corrective Action Plan, from the county department of social/human services, the Colorado
Department of Human Services,Audit Division,will review and either accept or reject the corrective action plan.
5.732.6 Corrective Action Plan[Rev.eft'.5/1/04]
A.Accepted Corrective Action Plan
If the plan is accepted,this decision will be indicated and the county department of social/human services will be notified via letter. At the
same time an e-mail notification will be sent to the Field Administration Division along with an electronic copy of the corrective action
plan.
B.Rejected Corrective Action Plan
If the plan is rejected by the Colorado Department of Human Services,Audit Division,the county department of social/human services will
be notified of the decision along with a new due date for an amended plan to be submitted.
C.Accepted Plan
Upon acceptance of new plan, the Colorado Department of Human Services, Audit Division will follow procedures outlined in Section
5.732.6.
D.Follow-Up
The Colorado Department of Human Services, Field Administration Division will verify that the county department of social/human
services has complied with the corrective action plan.
E.Closure
The Colorado Department of Human Services,Audit Division,will send a closure letter to the county director and,any applicable financial
adjustments to the Colorado Department of Human Services,Accounting Division to be processed in the State financial reporting system.
5.733 Appeal Process for Financial Compliance Reviews Performed and Management Decisions Issued by the Audit Division
5.733.1 Appeal in Writing[Rev.eff.5/1/04]
The appeal must be in writing and addressed to the Executive Director of the Colorado Department of Human Services, 1575 Sherman St.,
Denver, CO 80203. The basis for the appeal shall be limited to a factual error in the report or an incorrect interpretation of law, rule or
regulations.
5.733.2 Decision[Rev.eff.5/1/04]
The decision of the Executive Director of the Colorado Department of Human Services shall be the end of the appeal process.
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