Early this week, the Department of Health and Human Services (DHHS) Office of Inspector General (OIG) published findings and recommendations following a Title IV-E Adoption Assistance audit for the State of Tennessee Department of Children’s Services (DCS).  The audit covered fiscal years 2006 through 2008, examining 1,500 children during the period.  The OIG indentified 83 clients ineligible whose adoption assistance payment has been reimbursed federal funds.  The federal share for these 83 clients totaled $2.1 million in reimbursement.  The auditor also recommended that the state identify all additional payments made for the ineligible clients for FY 2009 and 2010 and submit a decreasing adjustment for the next quarterly report.  The report also indicates that 854 clients of the 1,500 sampled were set aside due to the lack of adequate documentation to make a determination of Title IV-E eligibility.  The amount of funds attributed to these clients totals $7.5 million, which OIG recommends that the Regional Office of ACF resolve with the state.  The auditor general further recommended that DCS continue to recover and restore missing documentation to eligibility files to support ongoing claiming of Title IV-E funding.  Other recommendations by OIG were to continue to strengthen internal controls to ensure that federal reimbursement for adoption assistance is sought only for eligible children and implement policies and procedures to ensure that adoption assistance records are retained in accordance with federal regulations. 

The findings of this audit are similar to other OIG audits performed around the country.  A high number of adoption subsidy files claiming Title IV-E reimbursement lack sufficient documentation to establish programmatic eligibility.  Many clients may have been receiving subsidy payments for more than 10 years and paperwork has been shifted from worker to worker and sometimes location to location.  Ensuring that the documentation is maintained may create challenges for many states because when adoptions are finalized, the files are often sealed and not accessible.   States must give careful consideration to how documents can be maintained and retrieved for the inevitable state audits and the prospect of a federal audit as well.  The level of information maintained in a state’s Statewide Automated Child Welfare Information System (SACWIS) may vary from state to state.