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Commonwealth of Virginia Single Audit Report for the Year Ended ...

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Responsible Party: Nancy Davis, DMV Contract and Procurement Director Jeff<br />

Ryan, DMV Assistant Commissioner <strong>for</strong> Finance<br />

Estimated Completion Date: June 1, 2012<br />

FEDERAL FINDINGS<br />

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES<br />

11-18: Support Title IV-E Financial Claims in a Client’s Case Record<br />

Applicable to: Department <strong>of</strong> Social Services<br />

Federal Program Name and CFDA#: Foster Care #93.658, Adoption Assistance #93.659<br />

Compliance Requirements: Sub-recipient Monitoring - 31 USC 7502(f) (2) (B)/A-133, Part 3, M.<br />

Sub-recipient Monitoring<br />

Type <strong>of</strong> Finding: Internal Control and Compliance<br />

In <strong>the</strong> prior year, we recommended that <strong>the</strong> Division <strong>of</strong> Family Services develop an<br />

en<strong>for</strong>cement mechanism to compel localities to provide support in a client’s case record <strong>of</strong> all foster<br />

care and adoption assistance Title IV-E payments. Be<strong>for</strong>e implementing <strong>the</strong> new policy, we<br />

recommended that management have it reviewed by <strong>the</strong> Secretary <strong>of</strong> Health and Human Resources<br />

to obtain <strong>the</strong> administration’s support <strong>for</strong> <strong>the</strong> change.<br />

We found <strong>the</strong> Division <strong>of</strong> Family Services per<strong>for</strong>med no reviews <strong>of</strong> locality reconciliations<br />

during fiscal 2011 to determine whe<strong>the</strong>r <strong>the</strong> client’s case record had support <strong>for</strong> payments. Fur<strong>the</strong>r<br />

management developed <strong>the</strong> policy without submitting it to <strong>the</strong> Secretary <strong>of</strong> Health and Human<br />

Resources <strong>for</strong> his consideration or support.<br />

As required by 45 CFR 1356.71, <strong>the</strong> case record must contain sufficient documentation to<br />

verify a child’s eligibility in order to substantiate payments. Without an en<strong>for</strong>cement mechanism to<br />

compel localities to link all payments to a client’s case record, <strong>the</strong> program will have disallowed<br />

costs. We again recommend that <strong>the</strong> agency develop an effective en<strong>for</strong>cement mechanism, with <strong>the</strong><br />

support <strong>of</strong> <strong>the</strong> Secretary <strong>of</strong> Health and Human Resources that ensures localities support each <strong>of</strong> <strong>the</strong>ir<br />

payments with a case record reflecting <strong>the</strong> client’s eligibility.<br />

Management Plan <strong>for</strong> Corrective Action <strong>for</strong> <strong>the</strong> Department <strong>of</strong> Social Services<br />

The <strong>Virginia</strong> Department <strong>of</strong> Social Services (VDSS), Division <strong>of</strong> Family Services<br />

(DFS), will require local departments <strong>of</strong> social services (LDSS) to provide monthly<br />

certification statements confirming that only eligible individuals are receiving foster<br />

care and adoption payments and confirm that proper documentation is entered into<br />

OASIS and <strong>the</strong> client’s case record. A progressively severe en<strong>for</strong>cement mechanism<br />

will be introduced at <strong>the</strong> start <strong>of</strong> State Fiscal <strong>Year</strong> (SFY) 2013 to hold localities<br />

accountable, (1) in <strong>the</strong>ir response to DFS to provide a certification as to <strong>the</strong> accuracy<br />

<strong>of</strong> <strong>the</strong> in<strong>for</strong>mation, and (2) certify that necessary documentation is included in <strong>the</strong><br />

client’s case record. Additionally, DFS will require LDSS to provide an electronic<br />

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