Jefferson County Government

Finding: Eligibility Federal Assistance Listing Number 93.558 - Temporary Assistance for Needy Families (TANF) Federal Agency - Department of Health and Human Services, Passed-Through Colorado Department of Human Services Award Number - None Provided; Award Year 2025 Criteria or Specific Requirement: The Temporary Assistance for Needy Families (TANF) program is governed by eligibility requirements established under the Social Security Act, applicable federal regulations (45 CFR Part 260-265), and corresponding State of Colorado policies. Pursuant to Uniform Guidance at 2 CFR §200.303, the County is required to establish and maintain effective internal controls over compliance to provide reasonable assurance that TANF eligibility determinations comply with all applicable federal statutes, regulations, and the terms and conditions of the federal award. All eligibility determinations must be fully supported by complete and accurate documentation and input correctly into the Colorado Benefits Management System (CBMS). Condition: We noted the following issues in the 25 cases tested: - One instance in which client income was incorrectly entered and as such, was ineligible for benefits as they were over the income limits for all of 2025. - Three instances in which, although case notes indicated general contact with the participant, the County did not retain sufficient documentation that a required meeting specifically addressed or confirmed engagement in an eligible work activity or was completed within required timeframe. Questioned Costs: $8,169 of known questioned costs were determined by isolating the benefits issued in 2025 for the client who was over income limits. Context: We tested 25 cases that received TANF assistance for the year ended December 31, 2025, and noted the issues described above. The tested sample represented approximately $145,000 in benefits issued. The total population consisted of approximately $6.3 million in benefits issued to approximately 2,013 clients. A non-statistical sampling methodology was used to select the sample. Effect: The absence of appropriate controls related to the above requirements increases the risk of incorrect benefit payments or the provision of inappropriate services to clients. Cause: There was a misunderstanding at the staff level of subsidized and unsubsidized employment income and the implications on TANF eligibility. In addition, there was inconsistent contact between the County and clients which resulted in incomplete documentation as required by State rule and County policy. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations. This includes issuing training alerts related to the differences between subsidized and unsubsidized employment income and the impacts to eligibility. Additionally, we recommend continued periodic quality assurance reviews of TANF case files to ensure ongoing compliance with federal and state eligibility requirements and identification of employees with performance issues. Finally, we recommend the County develop monitoring reports to identify those clients who have not had a workforce contact in the required timeframe. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Finding: Allowable Activities & Allowable Costs and Eligibility Federal Assistance Listing Number 93.658 – Foster Care-Title IV-E Department of Health and Human Services, Passed-Through Colorado Department of Human Services Award Number – None Provided; Award Year 2024 Criteria or Specific Requirement: Funds may be expended for foster care maintenance payments on behalf of eligible children, in accordance with the Title IV-E agency’s foster care maintenance payment rate schedule and in accordance with 45 CFR section 1356.21, to individuals serving as foster family homes, to childcare institutions, or public/private child-placement or child-care agencies. In accordance with Code of Colorado Regulations (CCR) section 7.302.2, for each child, Jefferson County Human Services (JCHS) must have an agreement with the provider which details the daily maintenance payments. JCHS agreement to purchases services must be signed by the provider and JCHS. Additionally, in accordance with CCR section 7.301.3, the Family Services Plan shall be reviewed in conference with the caseworker and supervisor every 90 calendar days.

Condition: During our testing, we noted the following:  Two instances out of 40 where there was no signed agreement in place to support revised maintenance payments following a child’s 9th birthday. The correct maintenance amount was paid to the provider in accordance with the state of Colorado rates published in IM-CW–2024-0028 and IM-CW-2023-0021.  One instance out of 40 where the required 90-day review was not completed on time. The review was conducted 15 days late. Questioned Costs: None. Context: We tested 40 foster care placements that received Title IV-E assistance for the year ended December 31, 2024, and noted the issues described above. The tested sample represented approximately $102,000 in benefits issued. The total population consisted of approximately $1.8 million in benefits issued to approximately 700 individuals. A non-statistical sampling methodology was used to select the sample.

Effect: The absence of appropriate controls related to the above requirements increases the risk of incorrect maintenance payments or the provision of inappropriate services to clients.

Cause: The state's foster care system did not automatically generate a notice that a new agreement to purchase services was needed based on the child's birthday. Additionally, JCHS lacks an effective control mechanism to proactively identify when a 90-day review is approaching or overdue. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that the County continue to strengthen internal controls related to eligibility determinations and maintenance payments. This includes evaluating the need for additional backup controls when relying on the state’s foster care system. Additionally, we recommend that JCHS submit help desk tickets to the state to report the system limitation regarding notifications for agreement updates based on a child's birthday. Views of Responsible Officials: We agree with the finding. See separate report for planned corrective actions.

Finding: Subrecipient Monitoring Federal Assistance Listing Number 21.023 COVID-19 Emergency Rental Assistance Program Department of Treasury Award Number - ERAE0226, Award Year 2021 Criteria: According to 2 CFR Part 200.332 - All pass through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and include various required information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. In addition, pass through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Finally, the pass through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: During testing, we noted the following: - The Assistance Listings number and Title were not provided to the County's two subrecipients in accordance with 2 CFR Part 200.332(a) - The County did not have a formal documented risk assessment completed for either of the County's two subrecipients in accordance with 2 CFR Part 200.332(b) - The County did not obtain or review one of the subrecipients single audit reports in accordance with 2 CFR Part 200.332(f) Questioned costs: None. Context: We tested the County's two subrecipients receiving $1,075,000 in subrecipient awards for the year ended December 31, 2023 and noted the issues above. A non-statistical sampling methodology was used to select the sample. Effect: The subrecipient may be unaware whether the funds are federal or what compliance requirements they are responsible for following. In addition, The County may not perform the adequate level of monitoring as formal risk assessments were not completed. Finally, the County did not review the single audit report and while any finding would not directly be related to the subaward program, failure to review such reports and take appropriate action could result in non-compliance by the subrecipient continuing for an inappropriate length of time.

Cause: The County does not have adequate internal controls over subrecipient monitoring to ensure that the County is in compliance with subrecipient monitoring requirements. Identification as a repeat finding: Not applicable. Recommendation: We recommend that the County develop a risk assessment template or form to be completed over each federal subrecipient. The County should provide training to those administering grants over the development risk assessment template or form and the associated monitoring to be performed based on each assessed risk. In addition, the County should develop a subrecipient grant template to help ensure all required information is included within each award. Finally, the County should establish a policy or procedure over obtaining and reviewing audits completed over each of their subrecipients. Views of responsible officials: The County agrees with the finding. See separate auditee document for planned corrective actions.