Maryland DHS Can't Document $1.3 Billion in Federal Revenue
Summary
Maryland's welfare and benefits agency, the Department of Human Services, closed out fiscal year 2025 with $1.31 billion in federal-fund revenue it booked but could not prove exists or is collectible, according to a December 2025 audit by the Maryland Office of Legislative Audits. That single agency's unsupported accrual equals nearly half of everything it actually spent in federal money that year, and it is one of four separate unresolved dollar findings against DHS in the same review -- alongside a $28 million unreported federal penalty, a $103.6 million account deficit, and $205 million in special-fund shortfalls. Statewide, seven Maryland agencies together booked $3.42 billion in federal revenue auditors could not verify, in a review whose own structure requires no formal corrective-action response.
The department's smaller net year-end accrual -- all its positive accruals minus its offsetting negative ones -- came to a separate $615 million, or 22.9% of that same spending, the figure the auditors themselves highlight. When an accrual that size can't be documented, the state doesn't actually know whether the federal government owes it that money, or whether Maryland's own general fund will eventually have to cover the gap.
How a $1.31 billion placeholder lands on the books
Every June 30, Maryland's Comptroller -- through its General Accounting Division (GAD) -- requires every state agency to zero out its federal-fund accounts for the year. If an agency spent more federal money than it has recorded revenue for, it books a positive accrual: a receivable, on the assumption Washington will pay up. GAD's own year-end closing instructions require that these entries reflect amounts collectible within 60 days of the fiscal year's end, and that agencies keep documentation to back each one up. The department recorded 45 positive accruals worth $2.23 billion at FY2025 close, netted against $1.61 billion in offsetting entries for a net accrual of $615 million. When OLA auditors tested five of the department's largest positive entries -- $1.31 billion combined, booked specifically to offset deficit account balances -- the department could not show the money was actually collectable from the federal government, nor that any of it had since arrived: as of September 2025, the department could point only to $386.3 million in federal receipts for fiscal year 2026, with no way to determine how much of that related to the flagged accruals versus new activity.
View data as table
| Dept. of Human Services (DHS) | 1,316,000,000 | about 49% of DHS's own FY2025 federal fund spending |
|---|---|---|
| Maryland Transit Admin. (MTA) | 755,100,000 | 91% of this had no executed federal grant as of June 30, 2025 |
| State Highway Admin. (SHA) | 600,000,000 | includes $330.4M in costs the feds never authorized |
| Dept. of Health (MDH) | 425,000,000 | 10 of 20 tested entries lacked support |
| Dept. of Education (MSDE) | 176,000,000 | unreimbursed expenditures exceeded the accrual by $51.3M |
| Emergency Management (MDEM) | 86,000,000 | approvals from other agencies still pending since July 2020 |
| Dept. of Labor (MDL) | 63,000,000 | $61M of it MDL itself calls unrecoverable |
One DHS account grew ten-fold while its spending stayed flat
Auditors singled out one of the department's accounts as their clearest example: it carried a $339.1 million revenue accrual at FY2025 close, against only $33.2 million the agency had actually spent from it that year -- about 10.2 times the account's real activity. That is not a one-year anomaly. The same account's year-end accrual climbed from $10.9 million in fiscal year 2020 to $306.9 million in fiscal year 2024, auditors' prior reviews found, even though annual expenditures out of it never topped $27 million in any of those five years. A revenue placeholder that outgrows the spending it is supposed to represent by that margin, year after year, stops looking like a timing gap and starts looking like a number nobody is checking.
The department wasn't the only agency whose year-end math strained credulity. Sized against each agency's own federal spending, the Maryland Transit Administration's accrual came to 201.5% of its entire FY2025 federal budget -- more than double what MTA actually spent, with 91% of the accrual tied to projects that didn't yet have an executed federal grant agreement. The department's 22.9% share looks almost restrained by comparison, but it's attached to the largest dollar figure of any agency in the review by a wide margin.
View data as table
| Maryland Transit Admin. | 201.5% | net accrual exceeds the agency's entire annual federal budget |
|---|---|---|
| Dept. of Labor | 90.7% | includes a deficit MDL itself already wrote off as unrecoverable |
| State Highway Admin. | 74.3% | up from a share consistent with $172.9M in FY2020 |
| Dept. of Emergency Mgmt. | 37.2% | tied to approvals other agencies haven't signed off on |
| Dept. of Education | 27.2% | MSDE could not explain the variance |
| Dept. of Human Services | 22.9% | the state's welfare and benefits agency |
| Dept. of Health | 6.2% | smallest share, but largest agency by dollar volume |
Three more unresolved dollar findings against the same agency
The $1.31 billion accrual wasn't the department's only problem in this review. Auditors found the department never reported $28 million in potential penalty liabilities to GAD, as state rules require: the U.S. Department of Agriculture's Food and Nutrition Service assessed the department $16.6 million in June 2024 and $11.4 million in June 2025 because Maryland's payment error rate -- the federal government's measure of how accurately a state determines eligibility and issues the correct benefit amount -- exceeded the national average for two straight years running, the threshold that triggers a penalty under federal rules. The department is appealing both penalties; as of November 2025, the federal government hadn't responded.
Separately, auditors found a $103.6 million deficit in a non-budgeted clearing account the department uses to sort general and federal assistance payments like Temporary Cash Assistance -- a deficit the department had not yet investigated as of October 2025, a year after the same issue was first flagged. And across five of the department's special funds, year-end account balances showed $205 million in deficits, including one $9.4 million shortfall identical, dollar for dollar, to what it had been the year before -- meaning nothing moved in that account for twelve straight months.
View data as table
| Unsupported federal revenue accrual | 1,316,000,000 | Finding 2 -- can't document it's collectable |
|---|---|---|
| Special-fund deficit balances | 204,963,053 | Finding 12 -- across 11 accounts, unresearched |
| Non-budgeted clearing-account deficit | 103,600,000 | Finding 11 -- same issue flagged a year earlier |
| Unreported SNAP penalty liability | 28,000,000 | Finding 10 -- never disclosed to the state's accountants |
A report designed to flag, not to fix
OLA's closeout review is a special report, not a full audit conducted under generally accepted government auditing standards -- and the auditors are explicit about what that means: this document carries zero formal recommendations, and agencies were not even asked for a written response to its findings. The corrective-action requirement lands instead in each agency's separate, periodic fiscal compliance audit, where the department's federal-accrual problems were already flagged once, in a compliance audit dated February 28, 2025. At the time of this closeout review, department management told auditors it was 'still working to implement corrective action' in response to that audit -- with no date attached to when that work finishes, and no penalty specified for how long it can run. Nine of this report's twelve findings are marked as repeats, in whole or part, of what OLA flagged in the prior year's review, the auditors say. The mechanism that produces this report is built to keep counting the gap, not to close it.
- Maryland's Department of Human Services closed fiscal year 2025 with $1.31 billion in federal-fund revenue accruals it could not document as collectible -- about 49% of everything the department actually spent in federal money that year (the department's smaller net year-end accrual, a different measure, was separately 22.9% of that spending), per a Maryland Office of Legislative Audits closeout review published December 18, 2025.
- One flagged department account carried a $339.1 million revenue accrual against just $33.2 million in real FY2025 spending -- a pattern auditors traced back to fiscal year 2020, when the same account's accrual was $10.9 million against expenditures that never exceeded $27 million in any of the next five years.
- The department also failed to report $28 million in potential federal -penalty liabilities, carried a $103.6 million deficit in an unresearched clearing account, and ran $205 million in special-fund deficits -- four separate unresolved dollar findings against one agency in one review, totaling roughly $1.65 billion in combined exposure.
- Statewide, seven of eight Maryland agencies OLA reviewed booked $3.42 billion in federal revenue auditors could not verify, plus $888 million in potential and $67 million in known unfunded liabilities -- equivalent to about 18.8% of the $18.1 billion those agencies spent in federal funds altogether that year.
- OLA's closeout report requires no formal agency response and contains no recommendations by design; the department's accrual problems were already flagged in a February 2025 compliance audit, and nine of this report's twelve findings are repeats of the prior year's -- with department management telling auditors only that corrective action is still in progress, with no completion date.
This OLA closeout review is a limited-scope "special report," not a full audit under generally accepted government auditing standards (GAGAS) -- it tests a sample of year-end entries for documentation and collectability, and its findings feed into each agency's separate, fuller compliance audit rather than standing alone as final determinations. Several of the dollar figures described as "unresolved exposure" -- the special-fund deficits, the clearing-account deficit, the unreported penalty -- are liabilities that may require Maryland general funds to resolve, per the auditors' own careful wording, not confirmed debts; some or all of the flagged federal accruals could still be collected. The $1.65 billion department total combines four distinct findings and should be read as the sum of separate unresolved dollar exposures in one review, not a single bill. Figures for fiscal year 2026 federal receipts (used to check whether FY2025 accruals were later collected) were only available through September or October 2025 at the time of the review, so the auditors themselves could not fully resolve collection status for any agency.
Sources(1) ▾
- Maryland Office of Legislative Audits, Department of Legislative Services, Statewide Review of Budget Closeout Transactions for Fiscal Year 2025 (2025-12-18) — The Legislative Auditor's annual special report to the Maryland General Assembly's Joint Audit and Evaluation Committee, signed by Legislative Auditor Brian S. Tanen, CPA, CFE. Reviews fiscal year 2025 budget closeout entries at eight State agencies -- testing whether year-end federal-fund revenue accruals are documented and collectible, and disclosing other significant closeout liabilities. Twelve numbered findings plus a summary exhibit; based on fieldwork September-November 2025 and agency records/interviews through October-November 2025. dls.maryland.gov · original document
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Maryland's Department of Human Services -- the state agency that runs , Temporary Cash Assistance, and child support enforcement for the state's poorest residents -- closed its books for fiscal year 2025 carrying $1.31 billion in federal-fund revenue it could not prove was real. That is the finding of the Maryland Office of Legislative Audits⧉ (OLA), the nonpartisan audit arm the General Assembly's Joint Audit and Evaluation Committee uses to check the state's books, in a special report on fiscal year 2025 budget closeout delivered December 18, 2025. The $1.31 billion is an accrued revenue entry -- an accounting placeholder Maryland agencies book at year's end for federal money they expect to collect but haven't received yet -- and it equals about 49% of everything the department actually spent in federal funds that year.