Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Housing and Urban Development (HUD) provides funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the CDBG program. The U.S. Department of Health and Human Services provides funding to DOA for LIHWAP. The CDBG program is intended to provide housing and expanded economic opportunities mainly for low- to moderate-income persons. LIHWAP provides financial assistance to low-income households for drinking water and wastewater service expenses.
CDBG and LIHWAP subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, program staff in DEHCR were responsible for tracking grant awards and providing that information to the Bureau of Financial Management, which reviewed and summarized the award information and reported the information to DOA’s Division of Executive Budget and Finance (DEBF). DEBF was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS). Beginning in March 2023, and in response to an audit finding related to FFATA reporting from our FY 2021-22 audit (report 23-4), DOA made changes in its FFATA reporting procedures.
Criteria:
Under 2 CFR s. 170, DOA is required to report subawards of $30,000 or more in FSRS, including any amendments or modifications to a subaward. This reporting must occur no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 9 of the 27 CDBG subawards DOA indicated were signed in FY 2022-23. Only one of the nine subawards selected for testing was reported in FSRS in a timely manner. One subaward that was made in June 2023 had not been reported in FSRS as of the time of our fieldwork in January 2024.
In addition, we reviewed the monthly spreadsheets DEHCR used to track subawards required to be reported in FSRS. To assess the accuracy and timeliness of reporting in FSRS, we selected 7 of the 72 subaward changes that were on the monthly spreadsheets in FY 2022-23. Although the original subawards were dated from July 2018 through June 2021, we found that DOA had entered into FSRS the original subaward for each of the seven sampled items in the period from February through May 2023. Further, four of the seven subaward amendments that required an update in FSRS had not been updated as of our fieldwork in January 2024.
Finally, for LIHWAP, DOA provided funding to one subrecipient. DOA entered into a subaward agreement for $500,000 with the subrecipient in November 2021. DOA amended the agreement in September 2022 to provide an additional $500,000, and again in March 2023 to provide an additional $250,000. However, DOA did not report the subaward or the amendments in FSRS until March 2023.
Context:
Of the $82.0 million DOA expended under the CDBG program during FY 2022-23, $80.9 million was provided to subrecipients. Of the $16.5 million DOA expended under LIHWAP during FY 2022-23, $0.6 million was provided to subrecipients. We interviewed DOA staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for reporting the information in FSRS. We requested subaward agreements and amendments, tracking spreadsheets, and reporting information from FSRS for each subaward to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the CDBG program and LIHWAP. DOA did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the CDBG program and LIHWAP.
Cause:
DOA staff indicated that one employee was responsible for the management of contracts for federal programs within DEHCR during the public health emergency. Due to the volume of federal funding being managed, DOA indicated it did not prioritize FFATA reporting.
In addition, one of the subawards that was not reported for the CDBG program was a subaward funded by program income. DOA did not believe that subawards funded with program income were required to be reported in FSRS. However, officials with HUD communicated to us in writing that subawards either partially or fully funded by program income are required to be reported in FSRS.
Finally, we note that we reported a finding related to FFATA reporting for the Low-Income Home Energy Assistance Program during our FY 2021-22 audit (report 23-4). DOA indicated that at the time we reported these concerns in February 2023, it had taken steps to review subaward agreements and amendments going back several years and to update FSRS.
Recommendation:
We recommend the Wisconsin Department of Administration:
- review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in FSRS in a timely manner; and
- develop and implement procedures to ensure subawards funded by program income for the Community Development Block Grant program are reported in the FFATA Subaward Reporting System accurately and in a timely manner or document why the subaward was exempt from FFATA reporting.
Finding 2023-100: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-DC-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Housing and Urban Development (HUD) provides funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the CDBG program. The U.S. Department of Health and Human Services provides funding to DOA for LIHWAP. The CDBG program is intended to provide housing and expanded economic opportunities mainly for low- to moderate-income persons. LIHWAP provides financial assistance to low-income households for drinking water and wastewater service expenses.
CDBG and LIHWAP subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, program staff in DEHCR were responsible for tracking grant awards and providing that information to the Bureau of Financial Management, which reviewed and summarized the award information and reported the information to DOA’s Division of Executive Budget and Finance (DEBF). DEBF was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS). Beginning in March 2023, and in response to an audit finding related to FFATA reporting from our FY 2021-22 audit (report 23-4), DOA made changes in its FFATA reporting procedures.
Criteria:
Under 2 CFR s. 170, DOA is required to report subawards of $30,000 or more in FSRS, including any amendments or modifications to a subaward. This reporting must occur no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 9 of the 27 CDBG subawards DOA indicated were signed in FY 2022-23. Only one of the nine subawards selected for testing was reported in FSRS in a timely manner. One subaward that was made in June 2023 had not been reported in FSRS as of the time of our fieldwork in January 2024.
In addition, we reviewed the monthly spreadsheets DEHCR used to track subawards required to be reported in FSRS. To assess the accuracy and timeliness of reporting in FSRS, we selected 7 of the 72 subaward changes that were on the monthly spreadsheets in FY 2022-23. Although the original subawards were dated from July 2018 through June 2021, we found that DOA had entered into FSRS the original subaward for each of the seven sampled items in the period from February through May 2023. Further, four of the seven subaward amendments that required an update in FSRS had not been updated as of our fieldwork in January 2024.
Finally, for LIHWAP, DOA provided funding to one subrecipient. DOA entered into a subaward agreement for $500,000 with the subrecipient in November 2021. DOA amended the agreement in September 2022 to provide an additional $500,000, and again in March 2023 to provide an additional $250,000. However, DOA did not report the subaward or the amendments in FSRS until March 2023.
Context:
Of the $82.0 million DOA expended under the CDBG program during FY 2022-23, $80.9 million was provided to subrecipients. Of the $16.5 million DOA expended under LIHWAP during FY 2022-23, $0.6 million was provided to subrecipients. We interviewed DOA staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for reporting the information in FSRS. We requested subaward agreements and amendments, tracking spreadsheets, and reporting information from FSRS for each subaward to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the CDBG program and LIHWAP. DOA did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the CDBG program and LIHWAP.
Cause:
DOA staff indicated that one employee was responsible for the management of contracts for federal programs within DEHCR during the public health emergency. Due to the volume of federal funding being managed, DOA indicated it did not prioritize FFATA reporting.
In addition, one of the subawards that was not reported for the CDBG program was a subaward funded by program income. DOA did not believe that subawards funded with program income were required to be reported in FSRS. However, officials with HUD communicated to us in writing that subawards either partially or fully funded by program income are required to be reported in FSRS.
Finally, we note that we reported a finding related to FFATA reporting for the Low-Income Home Energy Assistance Program during our FY 2021-22 audit (report 23-4). DOA indicated that at the time we reported these concerns in February 2023, it had taken steps to review subaward agreements and amendments going back several years and to update FSRS.
Recommendation:
We recommend the Wisconsin Department of Administration:
- review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in FSRS in a timely manner; and
- develop and implement procedures to ensure subawards funded by program income for the Community Development Block Grant program are reported in the FFATA Subaward Reporting System accurately and in a timely manner or document why the subaward was exempt from FFATA reporting.
Finding 2023-100: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-DC-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Crime Victim Assistance—Federal Funding Accountability and Transparency Act Reporting
Background:
DOJ receives federal funding from the U.S. Department of Justice for the Crime Victim Assistance program. The Crime Victim Assistance program provides funding to support direct services to victims of violent crime. DOJ subawards funds as part of administering this program.
Subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DOJ identified subawards subject to FFATA reporting using information from its grants administration system. DOJ staff provided that information to DOA’s Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DOJ is required to report in FSRS subawards of $30,000 or more under the Crime Victim Assistance program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 15 of 109 subawards DOJ made during FY 2022-23 under the Crime Victim Assistance program. None of the subawards we selected were reported in a timely manner in FSRS, including seven subawards that were reported one month late, seven subawards that were reported three or more months late, and one subaward that was not located in FSRS.
Context:
Of the $37.5 million DOJ expended under the Crime Victim Assistance program during FY 2022-23, $36.3 million was provided to subrecipients. We interviewed DOJ staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DOJ did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Crime Victim Assistance program. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Crime Victim Assistance program.
Cause:
DOJ did not provide FFATA reporting information to DOA in a timely manner. For the award that could not be located in FSRS, DOJ staff indicated that DOJ’s initial submission to DOA did not include the correct subrecipient identifier to report in FSRS. DOJ corrected this error in January 2023 and resubmitted the FFATA reporting information to DOA, which acknowledged receipt of the resubmitted information. DOJ did not determine why the corrected information was not in FSRS.
Recommendation:
We recommend the Wisconsin Department of Justice review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-900: Crime Victim Assistance—Federal Funding Accountability and Transparency Act Reporting
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Justice: The Wisconsin Department of Justice agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Labor provides funding to DWD for the WIOA Cluster, which includes the WIOA Adult Program, the WIOA Youth Activities program, and the WIOA Dislocated Worker Formula Grants program. This cluster is intended to provide a framework for delivery of workforce activities at the state and local levels to help job seekers access employment, education, training, and support services to succeed in the labor market. DWD subgrants funds under each program in the WIOA Cluster to local workforce development boards, and federal regulations allow for the transfer of funds between the WIOA Adult Program and WIOA Dislocated Worker Formula Grants program.
For the WIOA Cluster, subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DWD accountants were responsible for summarizing grant award information and providing that information to DOA for uploading into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DWD is required to report in FSRS subawards of $30,000 or more under each WIOA program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 27 subawards that were awarded by DWD under the WIOA Cluster during FY 2022-23, including original subawards and amendments to these subawards. We found that 2 of the 27 subawards selected for testing were not reported in FSRS in a timely manner. Although these two subawards were awarded in May 2023, they were not entered into FSRS at the time of our fieldwork in February 2024.
For the remaining 25 subawards, the date the subaward agreement was signed was reported incorrectly. Rather than reporting the date the subaward agreement was signed, DWD reported the date the subaward period began. This date was used incorrectly as the date the subaward agreement was signed for the initial subaward and for any amendments to a subaward.
Context:
Of the $31.7 million DWD expended under the WIOA Cluster during FY 2022-23, $23.9 million was provided to subrecipients. We interviewed DWD staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DWD did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS for the WIOA Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the WIOA Cluster.
Cause:
DWD staff indicated that a single employee was responsible for obtaining and summarizing data used in FFATA reporting for the WIOA Cluster, and no additional oversight or review was performed.
For the two subawards that were not reported, DWD staff indicated that these were transfers of award amounts between different WIOA programs. DWD was not aware that reporting is separate for each WIOA program subaward in FFATA and that these transfers were required to be reported.
Recommendation:
We recommend the Wisconsin Department of Workforce Development implement procedures for review and oversight of its Federal Funding Accountability and Transparency Act reporting to ensure all required subawards of $30,000 or more, including amendments or modifications, are identified and submitted in a timely manner and accurate award information, including the date the subaward agreement was signed, is reported.
Finding 2023-600: WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Workforce Development: The Wisconsin Department of Workforce Development agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Labor provides funding to DWD for the WIOA Cluster, which includes the WIOA Adult Program, the WIOA Youth Activities program, and the WIOA Dislocated Worker Formula Grants program. This cluster is intended to provide a framework for delivery of workforce activities at the state and local levels to help job seekers access employment, education, training, and support services to succeed in the labor market. DWD subgrants funds under each program in the WIOA Cluster to local workforce development boards, and federal regulations allow for the transfer of funds between the WIOA Adult Program and WIOA Dislocated Worker Formula Grants program.
For the WIOA Cluster, subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DWD accountants were responsible for summarizing grant award information and providing that information to DOA for uploading into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DWD is required to report in FSRS subawards of $30,000 or more under each WIOA program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 27 subawards that were awarded by DWD under the WIOA Cluster during FY 2022-23, including original subawards and amendments to these subawards. We found that 2 of the 27 subawards selected for testing were not reported in FSRS in a timely manner. Although these two subawards were awarded in May 2023, they were not entered into FSRS at the time of our fieldwork in February 2024.
For the remaining 25 subawards, the date the subaward agreement was signed was reported incorrectly. Rather than reporting the date the subaward agreement was signed, DWD reported the date the subaward period began. This date was used incorrectly as the date the subaward agreement was signed for the initial subaward and for any amendments to a subaward.
Context:
Of the $31.7 million DWD expended under the WIOA Cluster during FY 2022-23, $23.9 million was provided to subrecipients. We interviewed DWD staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DWD did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS for the WIOA Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the WIOA Cluster.
Cause:
DWD staff indicated that a single employee was responsible for obtaining and summarizing data used in FFATA reporting for the WIOA Cluster, and no additional oversight or review was performed.
For the two subawards that were not reported, DWD staff indicated that these were transfers of award amounts between different WIOA programs. DWD was not aware that reporting is separate for each WIOA program subaward in FFATA and that these transfers were required to be reported.
Recommendation:
We recommend the Wisconsin Department of Workforce Development implement procedures for review and oversight of its Federal Funding Accountability and Transparency Act reporting to ensure all required subawards of $30,000 or more, including amendments or modifications, are identified and submitted in a timely manner and accurate award information, including the date the subaward agreement was signed, is reported.
Finding 2023-600: WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Workforce Development: The Wisconsin Department of Workforce Development agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Labor provides funding to DWD for the WIOA Cluster, which includes the WIOA Adult Program, the WIOA Youth Activities program, and the WIOA Dislocated Worker Formula Grants program. This cluster is intended to provide a framework for delivery of workforce activities at the state and local levels to help job seekers access employment, education, training, and support services to succeed in the labor market. DWD subgrants funds under each program in the WIOA Cluster to local workforce development boards, and federal regulations allow for the transfer of funds between the WIOA Adult Program and WIOA Dislocated Worker Formula Grants program.
For the WIOA Cluster, subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DWD accountants were responsible for summarizing grant award information and providing that information to DOA for uploading into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DWD is required to report in FSRS subawards of $30,000 or more under each WIOA program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 27 subawards that were awarded by DWD under the WIOA Cluster during FY 2022-23, including original subawards and amendments to these subawards. We found that 2 of the 27 subawards selected for testing were not reported in FSRS in a timely manner. Although these two subawards were awarded in May 2023, they were not entered into FSRS at the time of our fieldwork in February 2024.
For the remaining 25 subawards, the date the subaward agreement was signed was reported incorrectly. Rather than reporting the date the subaward agreement was signed, DWD reported the date the subaward period began. This date was used incorrectly as the date the subaward agreement was signed for the initial subaward and for any amendments to a subaward.
Context:
Of the $31.7 million DWD expended under the WIOA Cluster during FY 2022-23, $23.9 million was provided to subrecipients. We interviewed DWD staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DWD did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS for the WIOA Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the WIOA Cluster.
Cause:
DWD staff indicated that a single employee was responsible for obtaining and summarizing data used in FFATA reporting for the WIOA Cluster, and no additional oversight or review was performed.
For the two subawards that were not reported, DWD staff indicated that these were transfers of award amounts between different WIOA programs. DWD was not aware that reporting is separate for each WIOA program subaward in FFATA and that these transfers were required to be reported.
Recommendation:
We recommend the Wisconsin Department of Workforce Development implement procedures for review and oversight of its Federal Funding Accountability and Transparency Act reporting to ensure all required subawards of $30,000 or more, including amendments or modifications, are identified and submitted in a timely manner and accurate award information, including the date the subaward agreement was signed, is reported.
Finding 2023-600: WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Workforce Development: The Wisconsin Department of Workforce Development agrees with the audit finding and recommendation.
Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments
Background:
The ERA Program was established in FY 2020-21 under the federal Consolidated Appropriations Act of 2021 and continued in FY 2021-22 and FY 2022-23 under ARPA. Treasury provided funding to DEHCR for the ERA Program. The program
was established to assist households that are unable to pay rent or utilities. DOA established the Wisconsin Emergency Rental Assistance (WERA) program using the federal ERA Program funding.
To administer the WERA program, DOA contracted with community action agencies and Energy Services, Inc. (ESI) to intake and review applications for eligibility. The community action agencies and ESI were responsible for entering the applications into DOA’s Home Energy (HE) Plus computer system, which was used to determine and process the benefit payment amount.
In both our performance evaluation of the ERA Program and Emergency Solutions Grant Program (report 22-3) and in our FY 2020-21 single audit (report 22-5), we identified concerns with DOA’s administration of the WERA program. We also identified continued concerns as part of our FY 2021-22 single audit (report 23-4) and recommended that DOA make improvements (Finding 2022-102 in report 23-4). In its response to our recommendations, DOA updated its policies and procedures in the WERA Program Manual and provided training to the community action agencies and ESI.
Criteria:
To be eligible for DOA’s WERA program, under Treasury guidance a household must be obligated to pay rent on a residential dwelling and:
-at least one individual within the household must qualify for unemployment benefits or experience a reduction in household income, incur significant costs, or experience other financial hardship because of the public health emergency; and
-at least one individual within the household must be at risk of experiencing homelessness or housing instability; and
-the household must be a low-income family as defined in 42 USC 1437a (b).
Treasury guidance allows the State to rely on self-attestation for verification of an applicant’s income. If a household meets the eligibility requirements based on a written attestation without further documentation, Treasury guidance indicates the State must redetermine household income every three months by requesting that applicants submit documentation or a written attestation.
Treasury guidance indicates that applicants must provide a current lease that is signed by the applicant and the landlord identifying the rental unit and the rental payment amount. If a lease is unavailable and the applicant cannot present documentation of the rental amount, Treasury guidance indicates that a written attestation may be accepted for up to three months. If additional assistance is needed after that time, documentation of the rental amount is required.
To make benefit payments under the WERA program, DOA requires:
-an income attestation form, which indicates that the applicant has been unable to pay rent and/or utilities and is at risk of losing housing or facing eviction, states that the applicant is not receiving other federally funded emergency rental assistance, and describes why income was affected;
-a renter verification form, which indicates the applicant’s name and applicant’s rental information, such as landlord, rental amount, and description of assistance requested; and
-supporting documentation, such as invoices, a lease agreement, or other documentation.
Further, when recertifying an applicant for eligibility after three months, DOA’s WERA Program Manual indicates that the applicant’s current income must be reviewed, notes are required to be entered into HE Plus indicating how the income eligibility was calculated, and an updated renter verification form is to be uploaded into HE Plus.
Condition:
We tested a random sample of 60 applicants who applied for and received benefits under the WERA program. In our testing, we found that DOA did not have sufficient documentation in HE Plus to demonstrate that four of the applicants were eligible to receive benefits under the program or that the costs were allowable under the ERA Program. We found concerns with:
-the income attestation form for 1 of 60 applicants in our sample where DOA did not have documentation in HE Plus of a completed income attestation form;
-the income recertification documentation for 2 of 60 applicants in our sample where DOA did not have documentation in HE Plus that a timely income recertification was completed; and
-the renter verification form for 1 of 60 applicants in our sample where DOA did not have documentation in HE Plus of a completed renter verification form.
Context:
Of the $98.9 million in ERA Program benefit payments DOA processed using HE Plus in FY 2022-23, $87.5 million was made to either landlords or tenants. A total of 25,201 applicants were reported in HE Plus as having received rental assistance
benefit payments under the ERA Program in FY 2022-23.
We evaluated Treasury guidance related to the ERA Program, discussed the application procedures with DOA staff, and reviewed DOA’s WERA Program Manual. We selected a random sample of 60 applicants who received ERA Program benefits in FY 2022-23 and reviewed the available documentation in HE Plus.
Questioned Costs:
We question $15,056 in rental assistance payments for the four applicants we identified for whom DOA did not have adequate supporting documentation in HE Plus. We determined that questioned costs include:
-$4,400 in benefits paid for one applicant for whom DOA did not have documentation in HE Plus of a completed income attestation form;
-$9,571 in benefits paid for two applicants for whom DOA did not have documentation in HE Plus of a timely income recertification; and
-$1,085 in benefits paid for one applicant for whom DOA did not have documentation in HE Plus of a renter verification form.
We also question an undetermined amount for applicants that we did not test.
Effect:
DOA provided rental and utility assistance to applicants who may have been ineligible to receive ERA Program benefits, which may have resulted in improper payments.
Cause:
During FY 2022-23, DOA did not provide adequate management oversight of ESI and the community action agencies that were responsible for entering the applicant information into HE Plus to ensure the appropriate supporting documentation was entered into the system. Supporting documentation was either not obtained or not included in HE Plus by the community action agencies or ESI.
Recommendation:
We recommend the Wisconsin Department of Administration:
-obtain the required documentation for the four applicants we identified or seek to recoup improper benefit payments it made to these applicants; and
-provide additional training and technical assistance to the community action agencies and Energy Services, Inc. (ESI) on the adequacy of supporting documentation that is to be obtained and entered into Home Energy (HE) Plus by the community action agencies and ESI.
Finding 2023-102: Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments
COVID-19—Emergency Rental Assistance Program
(Assistance Listing number 21.023)
Award Number Award Year
None 2021
Questioned Costs: $15,056, Plus an Undetermined Amount
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Emergency Rental Assistance Program—Subrecipient Monitoring
Background:
The ERA Program was established in FY 2020-21 under the federal Consolidated Appropriations Act of 2021 and continued in FY 2021-22 and FY 2022-23 under ARPA. Treasury provided funding to DEHCR for the ERA Program. The program was established to assist households that are unable to pay rent or utilities. DOA established the WERA program using the federal ERA Program funding.
To administer the WERA program, DOA contracted with community action agencies and ESI to intake and review applications for eligibility. The community action agencies and ESI were responsible for entering the applications into DOA’s HE Plus computer system, which was used to determine and process the benefit payment amounts.
Criteria:
Section 2 CFR s. 200.332 (d) through (f) requires DOA to monitor the activities of the community action agencies and ESI as necessary to ensure that the community action agencies and ESI use the subaward for authorized purposes, take timely and appropriate action on all deficiencies detected through monitoring, and comply with the terms and conditions of the subaward.
DOA’s policies and procedures for monitoring the community action agencies and ESI under the WERA program require DOA staff to review approximately four percent of all WERA applications weekly to assess that the documentation is accurate and complete, and that the applicants are eligible. DOA staff are required to outreach to the staff at the community action agencies or ESI to resolve any omission or error. The community action agencies or ESI is required to take corrective action, which may include obtaining documentation and adding it to HE Plus within seven to ten business days.
Condition:
During FY 2022-23, DOA did not perform all monitoring required by federal regulations or its policies and procedures. We found that DOA did not complete monitoring of the community action agencies between February 2023 and June 2023. Further, DOA only completed monitoring of ESI during the months of January 2023 and June 2023.
For the monitoring DOA did complete in FY 2022-23, we reviewed the documentation for seven of the weeks and found that DOA staff identified 69 applications where the community action agency or ESI did not include sufficient documentation in HE Plus to demonstrate that the applicant was eligible to receive benefits under the program or that the costs were allowable to be funded by the WERA program.
We reviewed 21 of the 69 applications for which DOA had identified documentation concerns and found that 16 of the 21 had not been resolved in HE Plus at the time of our fieldwork in February 2024. The documentation concerns were identified in DOA’s monitoring reviews, which took place in August 2022, October 2022, and January 2023. When we requested documentation of DOA’s communications with the community action agencies or ESI, DOA staff told us they did not communicate the results of the reviews to the community action agencies or ESI.
Context:
In FY 2022-23, DOA processed $98.9 million in ERA Program benefit payments using HE Plus. A total of 25,201 applicants were reported in HE Plus as having received benefit payments under the ERA Program in FY 2022-23.
We reviewed and discussed DOA’s procedures for tracking and completing monitoring for the community action agencies and ESI. We also evaluated the monitoring completed in FY 2022-23. We selected 21 of the 69 applications for which DOA’s weekly monitoring identified documentation concerns, missing signatures, or other errors and for which the applicant received ERA Program benefits in FY 2022 23. We reviewed available documentation related to these applications in HE Plus.
Questioned Costs:
We question an undetermined amount for individuals that DOA identified in their monitoring of the community action agencies or ESI that did not have sufficient documentation in HE Plus.
Effect:
Because DOA did not ensure the community action agencies and ESI were taking timely and appropriate action on the deficiencies detected through monitoring for the ERA Program, there is a higher risk that DOA, ESI, and the community action agencies are not in compliance with all federal requirements. In addition, DOA provided rental assistance to applicants who may have been ineligible to receive ERA Program benefits, which may have resulted in improper payments.
Cause:
DOA staff indicated that monitoring of ESI was inadvertently missed. In addition, DOA indicated that monitoring was temporarily stopped between February 2023 and June 2023 because of a temporary pause in accepting new WERA applications in HE Plus as ESI and community action agencies processed a backlog of existing WERA applications. However, the processing of backlogged applications created new applications in HE Plus that required monitoring. In addition, DOA did not have adequate management oversight to ensure its established monitoring procedures were being followed. DOA noted that there was no procedure in place for management oversight of the monitoring program in FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Administration:
-review its existing monitoring procedures and ensure adequate management oversight procedures are established, documented, and followed;
-complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) identified by its existing monitoring procedures; and
-consider if additional monitoring should be completed for the community action agencies or ESI for the months during FY 2022-23 when the Department of Administration paused monitoring for the Emergency Rental Assistance Program.
Finding 2023-103: Emergency Rental Assistance Program—Subrecipient Monitoring
COVID-19—Emergency Rental Assistance Program (Assistance Listing number 21.023)
Award Number Award Year
None 2021
Questioned Costs: Undetermined
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Homeowner Assistance Fund—Service Organization Internal Controls
Background:
Under the American Rescue Plan Act (ARPA) of 2021, the U.S. Department of the Treasury (Treasury) provided funding to DOA’s DEHCR for HAF. This program was established to mitigate financial hardships associated with the public health emergency, including for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, losses of utilities or home energy services, and displacements of homeowners experiencing financial hardship after January 21, 2020.
Criteria:
Under 2 CFR 200.303, DOA is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the award terms and conditions. This includes instances in which management contracts with a service organization, which is an organization that provides services to another entity and whose services are relevant to the entity’s internal controls. For example, DOA contracted with a service organization to host and maintain a computer system to assist in determining the eligibility of individuals applying for HAF benefits, approving these benefits, storing information on HAF applicants, and for reporting HAF activities to the federal government.
When using a service organization, the entity should gain assurances that the internal controls at the service organization are operating effectively because weaknesses in the service organization’s internal controls could affect the activity of the entity. Such assurances could be gained through a service organization audit, which includes a report on the service organization’s internal controls by an independent auditor. One type of audit that may be completed includes an opinion on the fairness of management’s description of the internal controls in place at the service organization, whether the auditor believes the service organization’s internal controls are suitably designed to achieve the internal control objectives, and whether the service organization’s internal controls are effective at achieving the internal control objectives. In addition, an entity relying on a service organization audit report should review the complementary user entity controls referenced in the report and ensure these controls or others are in place at the entity.
If an entity relying on a service organization does not obtain a service organization audit report, the entity should ensure it has assessed the work being completed by the service organization, and has implemented procedures to ensure both the accuracy of processing completed by the service organization and the information provided by the service organization.
Condition:
DEHCR did not proactively obtain a service organization audit report from its service organization for HAF, nor did it perform other procedures sufficient to assess and reduce risk. In June 2023, DEHCR provided us with a June 2022 service organization audit report that covered the period November 25, 2021, to May 31, 2022. Since this report did not test whether the service organization’s internal controls were operating effectively for FY 2022-23, in October 2023 we asked DEHCR to provide us with the subsequent service organization audit report. In response to our additional inquiries, DEHCR contacted the service organization to obtain the report. In November 2023, DEHCR provided us with the September 2023 service organization audit report, which tested whether internal controls of the service organization were operating effectively for the period June 1, 2022, to May 31, 2023.
DECHR did not provide documentation to evidence that it had reviewed the June 2022 or September 2023 service organization audit reports. DEHCR staff indicated they reviewed the service organization audit reports and contacted the service organization in December 2023 to discuss the findings presented in the September 2023 report after we had requested the report. In January 2024, DEHCR staff indicated they had not documented their review and assessment of either the June 2022 or September 2023 service organization audit reports. DEHCR also did not provide documentation to evidence that it had reviewed the complementary user entity controls that are important for DEHCR to have in place in order to rely on the service organization audit report.
Context:
During FY 2022-23, DOA expended $47.8 million in HAF funding. DOA reported that $43.9 million, or 91.8 percent, of the expenditures were benefit payments to various entities, including mortgage and utility companies, on behalf of individuals who had their eligibility determinations processed by the computer system maintained by DOA’s service organization. We reviewed and discussed with DEHCR its procedures for determining eligibility for HAF, including its reliance on the computer system maintained by the service organization.
Questioned Costs:
None.
Effect:
DOA and the federal government cannot be assured that the service organization controls are effective in determining eligibility or completing federal reporting for HAF.
Cause:
DOA did not have sufficient procedures in place to obtain the service organization audit report from its service organization for HAF nor to use the service organization audit report as a tool to assess effectiveness of the internal controls for the computer system maintained by the service organization. While DOA’s contract with the service organization required the service organization to have an annual independent audit completed, the service organization was required to provide the service organization audit report to DOA upon request. In addition, DOA did not have sufficient procedures to ensure DEHCR reviewed that the complementary user entity controls referenced in the service organization audit report are in place.
Recommendation:
We recommend the Wisconsin Department of Administration develop and implement procedures to:
-obtain the service organization audit report for the computer system used to administer the Homeowner Assistance Fund;
-complete a review of the service organization audit report, assess the effectiveness of the internal controls on the computer system maintained by the service organization, and document its review; and
-complete a review of the complementary user entity controls at the Department of Administration that are required to be in place for it to rely on the service organization audit report, document its review, and implement user entity controls, if needed.
Finding 2023-101: Homeowner Assistance Fund—Service Organization Internal Controls
COVID-19—Homeowner Assistance Fund (Assistance Listing number 21.026)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Material Weakness, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments
Background:
Under ARPA, Treasury provided funding to DEHCR for HAF. This program was established to mitigate financial hardships associated with the public health emergency, including for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, losses of utilities or home energy services, and displacements of homeowners experiencing financial hardship after January 21, 2020.
To administer HAF, DOA contracted with a service organization to host and maintain a computer system to assist in determining the eligibility of individuals applying for benefits and approving these benefits. In addition, DOA contracted with community action agencies to intake and review individual applications for eligibility. The community action agencies were responsible for entering the applications into the computer system and following DOA’s policies and procedures regarding documentation requirements.
Criteria:
To be eligible for HAF under Treasury guidance, a homeowner must have experienced a financial hardship after January 21, 2020, and have income equal to or less than 150 percent of the area median income or 100 percent of the median income for the United States, whichever is greater.
Treasury guidance indicates two permissible approaches for income verification:
-a written attestation of household income and supporting documentation, such as paystubs, W-2 or other wage statements, IRS Form 1099s, tax filings, or an attestation from an employer; or
-a written attestation of household income and a reasonable fact-specific proxy for household income, such as reliance on data regarding average incomes in the household’s geographic area.
In its Wisconsin Help for Homeowners Program (WHH) Manual, DOA indicates two permissible approaches to document income eligibility:
-a written attestation of household income and documentation such as paystubs, W-2 or other wage statements, IRS Form 1099s, tax filings, or an attestation from an employer; or
-a written attestation of household income and the applicant’s most recent IRS tax return.
Condition:
We tested a sample of 60 applicants who applied for and received benefits under HAF during FY 2022-23. We found two applicants DOA approved for benefits that, based on the documentation in the HAF program computer system, did not meet the income eligibility documentation requirements. For one applicant, there was no documentation of a completed income attestation with supporting documentation at the time DOA approved the benefit payment. For another applicant, the documentation in the computer system showed the household’s income was greater than 100 percent of the median income based on the household size reported at the time of application.
Context:
DOA expended $47.8 million in HAF funding during FY 2022-23. DOA reported that $43.9 million, or 91.8 percent, of the expenditures were benefit payments made on behalf of applicants to various entities, including mortgage and utility companies. We evaluated Treasury guidance related to HAF, discussed the application procedures with DOA staff, and reviewed DOA’s WHH Manual. We selected a random sample of 60 applicants who received HAF benefits in FY 2022-23, and we reviewed available documentation in the HAF program computer system.
Questioned Costs:
We question $10,886 in water, gas, electrical, and mortgage assistance benefits paid on behalf of two applicants for whom DOA did not have adequate supporting income documentation at the time of benefit approval in the HAF program computer system. We also question an undetermined amount for applicants that we did not test.
Effect:
DOA provided homeowner assistance to applicants who may not have been eligible to receive HAF benefits, which may have resulted in improper payments.
Cause:
Prior to approving the benefit payments during FY 2022-23, DOA did not complete a sufficient review to ensure there was adequate supporting documentation entered into the HAF program computer system by the community action agencies. Supporting documentation was either not obtained and evaluated or was obtained but not included in the HAF program computer system by the community action agencies.
After we brought these exceptions to the attention of DOA, staff reached out to the applicants. Based on the additional information provided, DOA determined the applicants were eligible for HAF.
Recommendation:
We recommend the Wisconsin Department of Administration:
-revise its procedures to ensure the Department of Administration completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment; and
-provide training or other technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system.
Finding 2023-104: Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments
COVID-19—Homeowner Assistance Fund (Assistance Listing number 21.026)
Award Number Award Year
None 2021
Questioned Costs: $10,886, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from Treasury. CSLFRF was created under ARPA and is administered by DOA. CSLFRF funding has certain requirements, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF.
Criteria:
Under 2 CFR s. 200.303, DOA is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DOA is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DOA must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
Condition:
In our review of expenditures under the CSLFRF program, we identified unallowable costs that were charged to the CSLFRF program. We found:
-DOA overpaid one school district by $10,279 for the Get Kids Ahead K-12 Mental Health Initiative;
-DOA overpaid one local law enforcement agency by $129,595 for the Law Enforcement Assistance Program; and
-DOA overpaid one local law enforcement agency by $1,188 for the Law Enforcement Assistance Program.
Context:
During FY 2022-23, the State expended $747.5 million in CSLFRF funding. DOA expended $419.8 milion, including $15.5 million under the Get Kids Ahead K-12 Mental Health Initiative and $6.1 million under the Law Enforcement Assistance Program. We reviewed a sample of expenditures under each of these programs, assessed the supporting documentation, and inquired of DOA staff regarding the expenditues.
Questioned Costs:
$141,062
Effect:
DOA may have charged unallowable costs to the CSLFRF program, which may have resulted in improper payments.
Cause:
The overpayment to the school district under the Get Kids Ahead K-12 Mental Health Initiative resulted from an error in the upload of the payment in STAR, the State’s accounting system.
The overpayment to the law enforcement agency resulted because staff paid the full allocation of $144,744 to the agency, rather than the request for reimbursement of $15,149. The second overpayment resulted from an error made by DOA when addressing the correction for an amount reported in the expense report of a law enforcement agency.
Recommendation:
We recommend the Wisconsin Department of Administration ensure only allowable costs are charged to federal grant programs, and work with the U.S. Department of the Treasury to resolve the questioned costs we identified related to the Coronavirus State and Local Fiscal Recovery Funds program.
Finding 2023-105: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $141,062
Type of Finding: Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22 from the U.S. Department of the Treasury (Treasury). CSLFRF was created under ARPA and is administered DOA. CSLFRF funding has certain stipulations, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA entered into a memorandum of understanding (MOU) with DHS to administer several different programs to be funded by the CSLFRF program, including the DHS COVID Operations Funding Program, and entered into two agreements related to providing funding for the purchase of COVID-19 testing supplies and the laboratory diagnostic services necessary to complete testing of samples. Under the COVID-19 LAB Testing and Specimen Collection Program, funding was used to purchase COVID-19 testing supplies and to contract with vendors to transport testing supplies, collect specimens, and to test the specimens for COVID-19. Under the COVID-19 Testing Pilot Program, DHS contracted with local and tribal public health agencies and their partner health care providers, which DHS calls community partners, to reimburse costs associated with conducting COVID-19 testing at community testing sites.
Criteria:
In accordance with 2 CFR s. 200.303, DHS is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DHS is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DHS must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
ARPA stipulates that eligible expenditures under CSLFRF must be incurred between March 3, 2021, and December 31, 2024, and expended by December 31, 2026.
Condition:
DHS staff indicated that under the COVID-19 LAB Testing and Specimen Collection Program, staff reconciled vendor invoices to the Wisconsin Electronic Disease Surveillance System (WEDSS) data to ensure the amounts billed from the vendor are accurate and are based on testing completed. WEDSS is the DHS application to collect information on communicable diseases and includes reporting on COVID-19 testing. For 1 of 13 invoices we reviewed for this program, DHS did not have documentation to support that a reconciliation was completed. Further, for this same invoice, a portion of the tests were provided outside of the period of performance for the CSLFRF program.
For the COVID-19 Testing Pilot Program, DHS staff reviewed invoices from its community partners for reasonableness and approved the invoices for payment. However, DHS did not have sufficient procedures specifying how staff reviewed and approved the invoices. For five of seven invoices tested for this program, DHS did not have sufficient supporting documentation in STAR to demonstrate staff had reviewed the invoices for overall reasonableness, such as by reviewing WEDSS data, when available, or by asking the community partner for more detail to support the invoice.
We requested WEDSS or other data from DHS to support the invoices. For one invoice, DHS provided documentation of the results of a reconciliation between the community partner invoice and WEDSS data. For two invoices, DHS provided documentation that indicated more tests were recorded in WEDSS than those for which the community partner had requested reimbursement on its invoice.
For one invoice, which totaled $4,560, DHS did not provide any additional documentation to support that the tests were reported in WEDSS. For one other invoice, DHS paid the tribal public health agency $94,300 based on an invoice without detailed support for the number of tests. DHS indicated that the tribal public health agency used a different reporting system, but DHS did not have documentation to support the invoice. Further, a portion of the testing was performed outside of the period of performance for the CSLFRF program.
Finally, we found DHS charged costs from DOA central billings related to software license fees for the period July 1, 2020, through June 30, 2021, to CSLFRF funding under the DHS COVID Operations Funding Program. We estimate that $2,965 of
these charges were incurred prior to March 3, 2021, and were outside the period of performance for the CSLFRF program.
Context:
During FY 2022-23, DHS expended $125.6 million in CSLFRF funding, including $16.7 million under the DHS COVID Operations Funding Program and a total of $32.9 million related to the COVID-19 Testing Pilot Program and the COVID-19
LAB Testing and Specimen Collection Program. We interviewed DHS staff to gain an understanding of DHS’s administration of the CSLFRF funding, including how it reviewed invoices related to the testing programs. We requested documentation of
the WEDSS reconciliations and other support for the payments made for the testing programs.
We also reviewed unusual line descriptions in the accounting data and found the references to FY 2020-21 payments, which resulted in the identification of the DOA central billings. We discussed the underlying expenses with DHS staff to further understand if they were incurred outside of the period of performance.
Questioned Costs:
We question $103,671, which consists of:
-$94,300 paid to a community partner under the COVID-19 Testing Pilot Program;
-$4,560 paid to a community partner under the COVID-19 Testing Pilot Program;
-$2,965 related to the software license costs that were charged to the DHS COVID Operations Funding Program outside of the period of performance; and
-$1,846 paid for testing completed outside of the period of performance for one of the testing laboratories under the
COVID-19 LAB Testing and Specimen Collection Program.
In addition, we question an undetermined amount related to the invoices for which DHS provided documentation to indicate that testing had occurred but for which it did not complete a full reconciliation.
Effect:
DHS may have charged unallowable costs to the CSLFRF program, resulting in improper payments.
Cause:
DHS staff indicated that turnover of the employees who administered these programs in 2022 made it difficult for DHS to answer our questions and to obtain any further documentation. DHS staff noted that staff approving the invoices would not have had an awareness of the period of performance requirements for the CSLFRF program. DHS staff noted that the two testing programs were administered by different units within DHS and different procedures had been followed prior to FY 2022-23. Further, staff indicated that procedures were changed for these two programs in FY 2022-23 and that the invoices we had questioned were approved during that transition period. We note that the invoices about which we made inquiries related largely to COVID-19 testing completed in FY 2021-22 that was billed to DHS but not processed and paid until early in FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-review its current procedures for approving invoices related to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program to ensure the steps required for approving invoices are appropriate and documented, and that documentation is maintained either in STAR or in a central location accessible in the event of employee turnover;
-take additional steps to ensure that expenditures charged to the CSLFRF program are within the period of performance;
-provide training to staff responsible for approving invoices to ensure staff understand what documentation is required to support approvals and the required period of performance for the CSLFRF program; and
-work with the Wisconsin Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the CSLFRF program.
Finding 2023-307: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $103,671, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from Treasury. CSLFRF was created under ARPA and is administered by DOA. CSLFRF funding has certain requirements, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA entered into a memorandum of understanding with DHS to use CSLFRF funding to administer the Emergency Medical Services (EMS) Financial Support program, which has two components:
-additional funding to DHS’s existing EMS Funding Assistance Program; and
-a one-time flexible grant program for emergency medical response services.
Criteria:
Under 2 CFR s. 200.303, DHS is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DHS is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DHS must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
Condition:
In our review of expenditures under the CSLFRF program, we identified costs charged to the CSLFRF program that were unallowable and costs that were outside of the period of performance. We found the following:
-For two providers, DHS reimbursed $12,210 but was unable to provide the expense reports or supporting documentation. We could not determine whether the costs were allowable or incurred within the period of performance.
-For one provider, DHS did not have documentation to support that $7,607 in costs were within the period of performance for the CSLFRF program.
Context:
During FY 2022-23, the State expended $747.5 million in CSLFRF funding. DHS expended $128.2 million, including $35.9 million under the Emergency Medical Services Financial Support program. We reviewed a sample of expenditures under this program, assessed supporting documentation, and inquired of DHS staff regarding the expenditures.
Questioned Costs:
$19,817
Effect:
DHS may have charged unallowable costs to the CSLFRF program, which may have resulted in improper payments.
Cause:
DHS either did not obtain or did not retain sufficient documentation to support the reimbursements. The process used to reimburse providers based on an expense report may have contributed to the lack of documentation.
Recommendation:
We recommend the Wisconsin Department of Health Services ensure it retains documentation to support the costs charged to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, and work with the Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs we identified.
Finding 2023-309: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $19,817
Type of Finding: Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA) and is administered by DOA. CSLFRF funding has certain requirements, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA expended funding under the CSLFRF program for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by the CSLFRF program. DOA entered into an MOU with DOT to fund certain DOT payroll costs for the State Patrol Overtime Pay Program.
Criteria:
Under 2 CFR s. 200.303, DOA and state agencies administering CSLFRF funding are responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DOA is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DOA and state agencies administering CSLFRF funding must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
Condition:
In our review of expenditures under the CSLFRF program, we identified unallowable costs that were charged to the CSLFRF program. We found that DOT charged $2,173 in salaries for employees not working in the State Patrol Division for the State Patrol Overtime Pay Program.
Context:
During FY 2022-23, the State expended $747.5 million in CSLFRF funding. DOT expended $1.4 million under the State Patrol Overtime Pay Program. We reviewed a sample of expenditures under this program, assessed the underlying support documentation, and inquired of DOT staff regarding the expenditures.
Questioned Costs:
$2,173
Effect:
DOT may have charged unallowable costs to the CSLFRF program, which may have resulted in improper payments.
Cause:
The unallowable costs related to the DOT State Patrol Overtime Pay Program resulted from a coding error in one pay period that resulted in certain job titles not associated with the State Patrol Division being included in the charge to the CSLFRF-funded program.
Recommendation:
We recommend the Wisconsin Department of Transportation ensure only allowable costs are charged to federal grant programs, and work with the Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the Coronavirus State and Local Fiscal Recovery Funds program.
Finding 2023-500: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $2,173
Type of Finding: Noncompliance
Response from the Wisconsin Department of Transportation: The Wisconsin Department of Transportation agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to
the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
DNR did not have documentation that it completed risk assessments for GLRI subrecipients during FY 2022-23. Although DNR reviewed subrecipient reimbursement requests and progress reports as its primary monitoring activity, the sufficiency of this level of monitoring cannot be assured without performing the required risk assessments. We also found that DNR did not obtain the single audit report from the Federal Audit Clearinghouse (FAC) or have documentation to support that it completed a review of the report for the largest subrecipient that received GLRI program funding in FY 2022 23.
Context:
DNR expended $13.2 million under the GLRI program during FY 2022-23, including $7.2 million that it provided to 18 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and subrecipients to identify whether DNR had communicated the required award information to subrecipients. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its subrecipients are not in compliance with all federal requirements.
Cause:
DNR did not have a plan to monitor subrecipients for the GLRI program based on subrecipient risk assessments. DNR attributed the lack of documented risk assessments for GLRI program subrecipients to its close working relationship with
the subrecipients and its reliance on program managers to assess and complete monitoring as needed.
In addition, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. DNR staff indicated that they relied on the subrecipient to notify DNR when a single audit
report was submitted to the FAC rather than DNR staff independently identifying and reviewing all relevant GLRI subrecipient single audit reports submitted to the FAC. Further, the DNR staff person completing single audit report reviews for DNR grant programs was not aware of all 18 GLRI subrecipients and had not requested this information in order to independently identify from the FAC those single audit reports that should have been reviewed.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop a written monitoring plan for the Geographic Programs - Great Lakes Restoration Initiative program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities performed.
Finding 2023-800: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E01568 2015
00E02252 2017
00E02288 2017
00E02348 2018
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
01E03010 2022
00E03149 2022
00E03187 2022
00E03252 2022
00E03250 2022
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to
the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
DNR did not have documentation that it completed risk assessments for GLRI subrecipients during FY 2022-23. Although DNR reviewed subrecipient reimbursement requests and progress reports as its primary monitoring activity, the sufficiency of this level of monitoring cannot be assured without performing the required risk assessments. We also found that DNR did not obtain the single audit report from the Federal Audit Clearinghouse (FAC) or have documentation to support that it completed a review of the report for the largest subrecipient that received GLRI program funding in FY 2022 23.
Context:
DNR expended $13.2 million under the GLRI program during FY 2022-23, including $7.2 million that it provided to 18 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and subrecipients to identify whether DNR had communicated the required award information to subrecipients. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its subrecipients are not in compliance with all federal requirements.
Cause:
DNR did not have a plan to monitor subrecipients for the GLRI program based on subrecipient risk assessments. DNR attributed the lack of documented risk assessments for GLRI program subrecipients to its close working relationship with
the subrecipients and its reliance on program managers to assess and complete monitoring as needed.
In addition, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. DNR staff indicated that they relied on the subrecipient to notify DNR when a single audit
report was submitted to the FAC rather than DNR staff independently identifying and reviewing all relevant GLRI subrecipient single audit reports submitted to the FAC. Further, the DNR staff person completing single audit report reviews for DNR grant programs was not aware of all 18 GLRI subrecipients and had not requested this information in order to independently identify from the FAC those single audit reports that should have been reviewed.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop a written monitoring plan for the Geographic Programs - Great Lakes Restoration Initiative program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities performed.
Finding 2023-800: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E01568 2015
00E02252 2017
00E02288 2017
00E02348 2018
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
01E03010 2022
00E03149 2022
00E03187 2022
00E03252 2022
00E03250 2022
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendations.
Education Stabilization Fund—ESSER Fund Reporting
Background:
The U.S. Department of Education provides funding to DPI for several subprograms of the Education Stabilization Fund grant program, which includes the Elementary and Secondary School Emergency Relief (ESSER) Fund (Assistance Listing number 84.425). The purpose of the ESSER Fund is to provide local educational agencies (LEAs), including charter schools, with emergency relief funds to address the effects of the public health emergency on elementary and secondary schools. The ESSER Fund includes three rounds of funding. ESSER I was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, ESSER II was created by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and ESSER III was created by the American Rescue Plan Act (ARPA).
DPI used the ESSER funding to address various LEA needs related to the public health emergency, including personal protective equipment, sanitation, and technology equipment. During FY 2022 23, DPI expended $469.1 million under the ESSER Fund, of which $12.4 million was expended under ESSER I, $204.8 million was expended under ESSER II, and $251.9 million was expended under ESSER III. During our FY 2020-21 audit, we issued Finding 2021-400 (report 22 5) related to a lack of documentation at DPI for the first annual ESSER report.
Criteria:
Under 2 CFR s. 200.303, DPI is required to establish and maintain effective internal controls over its federal programs to provide reasonable assurance that the federal programs are administered in compliance with federal laws and regulations as well as the terms and conditions of its federal awards. This includes effective internal controls over the preparation of reports for the federal government. Under 34 CFR s. 76.720 (b), DPI is required to submit an annual report to the U.S. Department of Education on the uses of ESSER funds. In addition, 34 CFR s. 76.730 requires that DPI retain supporting documentation for a federal award. In September 2022, DPI submitted its second ESSER annual report. This report was to include activity from March 13, 2020, through June 30, 2021.
Condition:
In its second annual ESSER report submitted during FY 2022 23, we identified that DPI reported inaccurate ESSER expenditure amounts for 6 of 26 LEAs whose underlying data we reviewed for the period January 1, 2021, through June 30, 2021. For example, for one LEA DPI reported $13.5 million in ESSER expenditures for the period January 1, 2021, through June 30, 2021, when information on expenditures within its grant management system reported $22.0 million in ESSER expenditures for that LEA during that period.
Context:
We interviewed DPI staff to gain an understanding of the procedures for preparing the ESSER Fund annual report and for submitting the report to the U.S. Department of Education. The reporting requires DPI to accumulate certain information for the 449 LEA receipients of ESSER funding. We requested copies of the information accumulated for the second ESSER annual report and used information from DPI’s grant management system to assess the accuracy of the amounts included in the reports. We selected 26 LEAs to review the reported information for the ESSER expenditures, which included the State’s largest LEA and 25 additional LEAs.
Questioned Costs:
None.
Effect:
DPI cannot be assured that it reported complete and accurate information to the
U.S. Department of Education on the State’s uses of ESSER funding.
Cause:
DPI indicated the data it compiled from the grant management system for the first annual ESSER report resulted in significant data quality issues that it had been identifying and correcting. One of the primary reasons for the data quality issues related to how ESSER funding allocated to private schools was compiled and extracted by the grant management system. We found DPI had addressed the data quality issues for reported LEA expenditures through December 31, 2020. However, ESSER expenditure data for the period from January 1, 2021, through June 30, 2021, included LEAs that had related private school allocations for which we identified errors. DPI acknowledged that errors could be present in certain LEA expenditure amounts when there was a private school allocation. However, to identify and correct such errors when compiling the second annual ESSER report, DPI had not completed a review of the grant management data for each LEA for the period from January 1, 2021, through June 30, 2021.
Recommendation:
We recommend the Wisconsin Department of Public Instruction make changes to its grant management system or develop alternative procedures to ensure that all expenditure information is accurately reported for the Elementary and Secondary
School Emergency Relief Fund program.
Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting
COVID-19—Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425D)
Award Numbers Award Years
S425D200044 2020
S425D210044 2021
Questioned Costs: None
COVID-19—American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425U)
Award Numbers Award Years
S425U210044 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendation.
Education Stabilization Fund—ESSER Fund Reporting
Background:
The U.S. Department of Education provides funding to DPI for several subprograms of the Education Stabilization Fund grant program, which includes the Elementary and Secondary School Emergency Relief (ESSER) Fund (Assistance Listing number 84.425). The purpose of the ESSER Fund is to provide local educational agencies (LEAs), including charter schools, with emergency relief funds to address the effects of the public health emergency on elementary and secondary schools. The ESSER Fund includes three rounds of funding. ESSER I was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, ESSER II was created by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and ESSER III was created by the American Rescue Plan Act (ARPA).
DPI used the ESSER funding to address various LEA needs related to the public health emergency, including personal protective equipment, sanitation, and technology equipment. During FY 2022 23, DPI expended $469.1 million under the ESSER Fund, of which $12.4 million was expended under ESSER I, $204.8 million was expended under ESSER II, and $251.9 million was expended under ESSER III. During our FY 2020-21 audit, we issued Finding 2021-400 (report 22 5) related to a lack of documentation at DPI for the first annual ESSER report.
Criteria:
Under 2 CFR s. 200.303, DPI is required to establish and maintain effective internal controls over its federal programs to provide reasonable assurance that the federal programs are administered in compliance with federal laws and regulations as well as the terms and conditions of its federal awards. This includes effective internal controls over the preparation of reports for the federal government. Under 34 CFR s. 76.720 (b), DPI is required to submit an annual report to the U.S. Department of Education on the uses of ESSER funds. In addition, 34 CFR s. 76.730 requires that DPI retain supporting documentation for a federal award. In September 2022, DPI submitted its second ESSER annual report. This report was to include activity from March 13, 2020, through June 30, 2021.
Condition:
In its second annual ESSER report submitted during FY 2022 23, we identified that DPI reported inaccurate ESSER expenditure amounts for 6 of 26 LEAs whose underlying data we reviewed for the period January 1, 2021, through June 30, 2021. For example, for one LEA DPI reported $13.5 million in ESSER expenditures for the period January 1, 2021, through June 30, 2021, when information on expenditures within its grant management system reported $22.0 million in ESSER expenditures for that LEA during that period.
Context:
We interviewed DPI staff to gain an understanding of the procedures for preparing the ESSER Fund annual report and for submitting the report to the U.S. Department of Education. The reporting requires DPI to accumulate certain information for the 449 LEA receipients of ESSER funding. We requested copies of the information accumulated for the second ESSER annual report and used information from DPI’s grant management system to assess the accuracy of the amounts included in the reports. We selected 26 LEAs to review the reported information for the ESSER expenditures, which included the State’s largest LEA and 25 additional LEAs.
Questioned Costs:
None.
Effect:
DPI cannot be assured that it reported complete and accurate information to the
U.S. Department of Education on the State’s uses of ESSER funding.
Cause:
DPI indicated the data it compiled from the grant management system for the first annual ESSER report resulted in significant data quality issues that it had been identifying and correcting. One of the primary reasons for the data quality issues related to how ESSER funding allocated to private schools was compiled and extracted by the grant management system. We found DPI had addressed the data quality issues for reported LEA expenditures through December 31, 2020. However, ESSER expenditure data for the period from January 1, 2021, through June 30, 2021, included LEAs that had related private school allocations for which we identified errors. DPI acknowledged that errors could be present in certain LEA expenditure amounts when there was a private school allocation. However, to identify and correct such errors when compiling the second annual ESSER report, DPI had not completed a review of the grant management data for each LEA for the period from January 1, 2021, through June 30, 2021.
Recommendation:
We recommend the Wisconsin Department of Public Instruction make changes to its grant management system or develop alternative procedures to ensure that all expenditure information is accurately reported for the Elementary and Secondary
School Emergency Relief Fund program.
Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting
COVID-19—Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425D)
Award Numbers Award Years
S425D200044 2020
S425D210044 2021
Questioned Costs: None
COVID-19—American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425U)
Award Numbers Award Years
S425U210044 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendation.
Education Stabilization Fund—ESSER Fund Reporting
Background:
The U.S. Department of Education provides funding to DPI for several subprograms of the Education Stabilization Fund grant program, which includes the Elementary and Secondary School Emergency Relief (ESSER) Fund (Assistance Listing number 84.425). The purpose of the ESSER Fund is to provide local educational agencies (LEAs), including charter schools, with emergency relief funds to address the effects of the public health emergency on elementary and secondary schools. The ESSER Fund includes three rounds of funding. ESSER I was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, ESSER II was created by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and ESSER III was created by the American Rescue Plan Act (ARPA).
DPI used the ESSER funding to address various LEA needs related to the public health emergency, including personal protective equipment, sanitation, and technology equipment. During FY 2022 23, DPI expended $469.1 million under the ESSER Fund, of which $12.4 million was expended under ESSER I, $204.8 million was expended under ESSER II, and $251.9 million was expended under ESSER III. During our FY 2020-21 audit, we issued Finding 2021-400 (report 22 5) related to a lack of documentation at DPI for the first annual ESSER report.
Criteria:
Under 2 CFR s. 200.303, DPI is required to establish and maintain effective internal controls over its federal programs to provide reasonable assurance that the federal programs are administered in compliance with federal laws and regulations as well as the terms and conditions of its federal awards. This includes effective internal controls over the preparation of reports for the federal government. Under 34 CFR s. 76.720 (b), DPI is required to submit an annual report to the U.S. Department of Education on the uses of ESSER funds. In addition, 34 CFR s. 76.730 requires that DPI retain supporting documentation for a federal award. In September 2022, DPI submitted its second ESSER annual report. This report was to include activity from March 13, 2020, through June 30, 2021.
Condition:
In its second annual ESSER report submitted during FY 2022 23, we identified that DPI reported inaccurate ESSER expenditure amounts for 6 of 26 LEAs whose underlying data we reviewed for the period January 1, 2021, through June 30, 2021. For example, for one LEA DPI reported $13.5 million in ESSER expenditures for the period January 1, 2021, through June 30, 2021, when information on expenditures within its grant management system reported $22.0 million in ESSER expenditures for that LEA during that period.
Context:
We interviewed DPI staff to gain an understanding of the procedures for preparing the ESSER Fund annual report and for submitting the report to the U.S. Department of Education. The reporting requires DPI to accumulate certain information for the 449 LEA receipients of ESSER funding. We requested copies of the information accumulated for the second ESSER annual report and used information from DPI’s grant management system to assess the accuracy of the amounts included in the reports. We selected 26 LEAs to review the reported information for the ESSER expenditures, which included the State’s largest LEA and 25 additional LEAs.
Questioned Costs:
None.
Effect:
DPI cannot be assured that it reported complete and accurate information to the
U.S. Department of Education on the State’s uses of ESSER funding.
Cause:
DPI indicated the data it compiled from the grant management system for the first annual ESSER report resulted in significant data quality issues that it had been identifying and correcting. One of the primary reasons for the data quality issues related to how ESSER funding allocated to private schools was compiled and extracted by the grant management system. We found DPI had addressed the data quality issues for reported LEA expenditures through December 31, 2020. However, ESSER expenditure data for the period from January 1, 2021, through June 30, 2021, included LEAs that had related private school allocations for which we identified errors. DPI acknowledged that errors could be present in certain LEA expenditure amounts when there was a private school allocation. However, to identify and correct such errors when compiling the second annual ESSER report, DPI had not completed a review of the grant management data for each LEA for the period from January 1, 2021, through June 30, 2021.
Recommendation:
We recommend the Wisconsin Department of Public Instruction make changes to its grant management system or develop alternative procedures to ensure that all expenditure information is accurately reported for the Elementary and Secondary
School Emergency Relief Fund program.
Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting
COVID-19—Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425D)
Award Numbers Award Years
S425D200044 2020
S425D210044 2021
Questioned Costs: None
COVID-19—American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425U)
Award Numbers Award Years
S425U210044 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Background:
CDC provides funding to DHS under the Cooperative Agreements program. The Cooperative Agreements program is intended to provide funding to rapidly respond to public health emergencies as identified by the CDC. DHS received three awards from the CDC to be funded by the Cooperative Agreements grant: COVID Crisis Response, COVID Public Health Workforce, and Monkey Pox Crisis Response.
Under the COVID Public Health Workforce award, DHS contracted with subrecipients, including local and tribal public health agencies and cooperative educational service agencies (CESAs), to administer the award. DHS uses CARS to process
the reimbursement requests for the local and tribal public health agencies. Reimbursement requests for CESAs are processed directly through STAR, the State’s accounting system, based upon review and approval of detailed invoices.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. DHS policies note that additional verification can be performed by reviewing subrecipients financial records through a desk review or an on-site visit.
Condition:
For 1 of 11 subrecipients we reviewed, DHS was unable to provide a completed subrecipient risk assessment. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there were no procedures to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when DHS would be required to review subrecipient invoices through a desk review or an on-site visit. DHS staff indicated that all subrecipients were monitored in the same manner regardless of the risk assessment level determined.
DHS monitoring of subrecipient activity for the Cooperative Agreements program was not documented sufficiently to provide assurance that the subrecipients used the subaward for authorized purposes and in compliance with the subaward terms and conditions. DHS grant program staff collected and reviewed semiannual progress and fiscal reports for the 96 local and tribal public health agencies that received funding under the COVID Public Health Workforce award, but did not require such reporting for the CESAs. We reviewed the spreadsheet maintained by the grant program staff to track and document review of the semiannual progress and fiscal reports submitted in December 2022. We found the documentation was incomplete. We identified that for 12 of the 96 subrecipients being tracked, the spreadsheet indicated that the review was still in progress at the time of our fieldwork in February 2024. We also identified that for four subrecipients, DHS indicated in the spreadsheet that costs were denied or potentially denied. However, DHS did not note a conclusion in the spreadsheet. We requested any documentation DHS had available related to resolution of the denied or potentially denied costs. DHS provided only limited documentation, including email correspondence with certain of the subrecipients. DHS was unable to provide documentation to support that it had resolved three of the four subrecipients potentially unallowable costs.
Finally, DHS did not review subrecipient invoices through a desk review or an on-site visit of the subrecipient to assess the allowability of the costs charged to the grant.
Context:
DHS expended $15.4 million under the Cooperative Agreements grant during FY 2022-23, including $6.8 million that was provided to subrecipients. Of the $6.8 million provided to subrecipients, $5.5 million was processed through CARS.
We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of CARS, and its policies and procedures for monitoring subrecipients to ensure costs are allowable to be charged to the grant program.
For the COVID Public Health Workforce grant, DHS contracted with 96 local and tribal public health agencies and 12 CESAs to administer the program.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Cooperative Agreements program. Further, there is an increased risk of improper payments for the Cooperative Agreements program.
Cause:
DHS program staff were unable to explain why a risk assessment was not performed for the one subrecipient that did not have a risk assessment. DHS management did not establish written procedures to guide program staff in assessing the extent of subrecipient monitoring necessary for each level of subrecipient risk. As a result, program staff did not adjust monitoring procedures for subrecipients based on the risk assessment.
DHS program staff indicated that staff turnover contributed to some of the issues with the subrecipient monitoring spreadsheet and the lack of documentation of decisions that were made. Further, DHS program staff relied on the CARS payment process to determine that costs were allowable to be charged to the grant program. However, CARS payments are processed based on high-level summaries from subrecipients and would not provide sufficient detail to assess whether the costs were allowable or not.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-review the tracking spreadsheets completed in fiscal year 2022-23, and complete the assessment of the progress and fiscal reports and consideration of potential unallowable costs, document the conclusions, and return funding to the federal government if costs were determined to be unallowable;
-develop a written monitoring plan for the Cooperative Agreements program that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting review of the progress and fiscal reports; procedures for completing and documenting desk reviews or on-site visits; procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report; and procedures for documenting management oversight of the monitoring plan;
-develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence; and
-provide sufficient training to Department of Health Services staff administering the Cooperative Agreements program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined.
Finding 2023-306: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Numbers Award Years
6 NU90TP922078-01 2020
1 NU90TP922132-01 2021
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
Background:
The DHHS Centers for Disease Control (CDC) provides funding to DHS under the Health Disparities program. The program is intended to address health disparities for high-risk and underserved populations to address COVID-19 related health disparities and advance health equity.
To administer the award under the Health Disparities program, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses CARS to process the reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or on-site visit.
Condition:
DHS did not establish sufficient procedures to ensure the requirements related to subrecipient risk assessments were met. Although we found that risk assessments were completed for subrecipients, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there were no procedures to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Staff indicated that the level of monitoring of subrecipients is determined by the program staff working with the subrecipient.
To ensure only allowable costs were funded by the program, the Health Disparities program staff indicated that they relied on the establishment of a contract with the subrecipient, which indicated the costs that were allowable for the program. Further, staff indicated that there were ongoing interactions with the subrecipients to ensure the funding was expended appropriately. DHS provided various examples of how individual program staff interacted with subrecipients through email, periodic meetings, and the receipt of progress reports. However, as monitoring to be completed was determined by an individual program staff member, there was no procedure to ensure adequate monitoring was completed or that monitoring was consistent. Further, the documentation DHS provided did not demonstrate management oversight to ensure adequate monitoring was completed.
DHS also did not review subrecipient invoices through a desk review or an on-site visit to assess the allowability of the costs charged to the grant.
Context:
DHS expended $9.6 million under the Health Disparities program during FY 2022-23, including $3.8 million that was provided to subrecipients and was processed through CARS. DHS contracted with 87 subrecipients to administer the program. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of CARS, and its policies and procedures for monitoring subrecipients to ensure costs are allowable to be charged to the grant program.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Health Disparities program. Further, there is an increased risk of improper payments for the Health Disparities program.
Cause:
DHS did not establish written procedures to guide program staff in assessing the extent of subrecipient monitoring necessary for each level of subrecipient risk. As a result, program staff did not adjust monitoring procedures for subrecipients based on the risk assessment.
DHS program staff relied on the CARS payment process and interactions with subrecipients to determine that costs were allowable to be charged to the Health Disparities program. Further, management oversight to ensure subrecipient monitoring was completed either did not occur or was not documented.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-develop a written monitoring plan for the Health Disparities program that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports; and procedures for documenting management oversight of the monitoring plan;
-develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence; and
-provide sufficient training to the Department of Health Services staff administering the Health Disparities program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined.
Finding 2023-305: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
1 NH75OT000039-01 2021
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Housing and Urban Development (HUD) provides funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the CDBG program. The U.S. Department of Health and Human Services provides funding to DOA for LIHWAP. The CDBG program is intended to provide housing and expanded economic opportunities mainly for low- to moderate-income persons. LIHWAP provides financial assistance to low-income households for drinking water and wastewater service expenses.
CDBG and LIHWAP subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, program staff in DEHCR were responsible for tracking grant awards and providing that information to the Bureau of Financial Management, which reviewed and summarized the award information and reported the information to DOA’s Division of Executive Budget and Finance (DEBF). DEBF was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS). Beginning in March 2023, and in response to an audit finding related to FFATA reporting from our FY 2021-22 audit (report 23-4), DOA made changes in its FFATA reporting procedures.
Criteria:
Under 2 CFR s. 170, DOA is required to report subawards of $30,000 or more in FSRS, including any amendments or modifications to a subaward. This reporting must occur no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 9 of the 27 CDBG subawards DOA indicated were signed in FY 2022-23. Only one of the nine subawards selected for testing was reported in FSRS in a timely manner. One subaward that was made in June 2023 had not been reported in FSRS as of the time of our fieldwork in January 2024.
In addition, we reviewed the monthly spreadsheets DEHCR used to track subawards required to be reported in FSRS. To assess the accuracy and timeliness of reporting in FSRS, we selected 7 of the 72 subaward changes that were on the monthly spreadsheets in FY 2022-23. Although the original subawards were dated from July 2018 through June 2021, we found that DOA had entered into FSRS the original subaward for each of the seven sampled items in the period from February through May 2023. Further, four of the seven subaward amendments that required an update in FSRS had not been updated as of our fieldwork in January 2024.
Finally, for LIHWAP, DOA provided funding to one subrecipient. DOA entered into a subaward agreement for $500,000 with the subrecipient in November 2021. DOA amended the agreement in September 2022 to provide an additional $500,000, and again in March 2023 to provide an additional $250,000. However, DOA did not report the subaward or the amendments in FSRS until March 2023.
Context:
Of the $82.0 million DOA expended under the CDBG program during FY 2022-23, $80.9 million was provided to subrecipients. Of the $16.5 million DOA expended under LIHWAP during FY 2022-23, $0.6 million was provided to subrecipients. We interviewed DOA staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for reporting the information in FSRS. We requested subaward agreements and amendments, tracking spreadsheets, and reporting information from FSRS for each subaward to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the CDBG program and LIHWAP. DOA did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the CDBG program and LIHWAP.
Cause:
DOA staff indicated that one employee was responsible for the management of contracts for federal programs within DEHCR during the public health emergency. Due to the volume of federal funding being managed, DOA indicated it did not prioritize FFATA reporting.
In addition, one of the subawards that was not reported for the CDBG program was a subaward funded by program income. DOA did not believe that subawards funded with program income were required to be reported in FSRS. However, officials with HUD communicated to us in writing that subawards either partially or fully funded by program income are required to be reported in FSRS.
Finally, we note that we reported a finding related to FFATA reporting for the Low-Income Home Energy Assistance Program during our FY 2021-22 audit (report 23-4). DOA indicated that at the time we reported these concerns in February 2023, it had taken steps to review subaward agreements and amendments going back several years and to update FSRS.
Recommendation:
We recommend the Wisconsin Department of Administration:
- review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in FSRS in a timely manner; and
- develop and implement procedures to ensure subawards funded by program income for the Community Development Block Grant program are reported in the FFATA Subaward Reporting System accurately and in a timely manner or document why the subaward was exempt from FFATA reporting.
Finding 2023-100: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-DC-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Refugee and Entrant Assistance State/Replacement Designee Administered Programs—Subrecipient Monitoring
Background:
DCF receives federal funding from DHHS for the Refugee Programs. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community.
To administer the Refugee Programs, DCF contracts with subrecipients, or partner agencies, located around the State. The partner agencies are responsible for completing eligibility determinations, determining and providing benefits, and referring refugees to other community resources that may assist them.
Criteria:
DCF administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DCF to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DCF to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DCF to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
Condition:
We found that DCF did not have documentation to support that it completed sufficient monitoring activities for 8 of the 25 subrecipients for the Refugee Programs during FY 2022-23. We also found that a risk assessment was not documented by DCF for one of the three subrecipients we reviewed for the Refugee Programs.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, it disbursed nearly $6.9 million to 25 subrecipients, including school districts, community centers, and social services agencies. DCF is responsible for performing subrecipient monitoring procedures for the recipients of these funds. We reviewed the agreements between DCF and subrecipients to identify whether DCF had communicated the required award information to subrecipients. We also reviewed monitoring activities performed by DCF for the Refugee Programs during FY 2022-23, including by gaining an understanding of the process DCF used for reviewing subrecipient single audit reports, the results of risk assessments completed for subrecipients, and the procedures used by DCF to monitor subrecipients through the on-site monitoring and programmatic desk reviews.
Questioned Costs:
None.
Effect:
Because DCF did not comply with all subrecipient monitoring compliance requirements for the Refugee Programs, there is a higher risk that DCF, as well as the subrecipients, are not in compliance with all federal requirements.
Cause:
DCF did not have a formal plan to monitor subrecipients for the Refugee Programs based on the risk assessment process. DCF staff in the Bureau of Refugee Programs indicated that they relied on risk assessments completed by DCF’s central audit function. However, DCF staff did not identify that risk assessments for some Refugee Programs subrecipients were not completed centrally because DCF’s central audit function does not complete risk assessments for subrecipients with expenditures below a certain threshold. DCF staff in the Bureau of Refugee Programs indicated they had performed a semiannual programmatic desk review for six of the eight subrecipients but were unable to provide documentation to evidence that such reviews were performed. DCF staff in the Bureau of Refugee Programs stated that the large increase in federal funds in the Refugee Programs and the introduction of several subprograms resulted in an increased workload for DCF staff who had to respond to other priorities of the program. According to DCF staff in the Bureau of Refugee Programs, this resulted in a reduction in the extent to which on-site monitoring could be performed.
Recommendation:
We recommend the Wisconsin Department of Children and Families:
-develop a subrecipient monitoring plan based on the risk assessment process to identify the specific monitoring steps necessary;
-establish and implement procedures to ensure risk assessments are completed for each subrecipient of the Refugee and Entrant Assistance State/Replacement Designee Administered Programs; and
-maintain documentation of all subreceipient monitoring activities performed.
Finding 2023-201: Refugee and Entrant Assistance State/Replacement Designee Administered Programs—Subrecipient Monitoring
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2201WIRCMA 2022
2301WIRCMA 2023
2101WIRSSS 2021
2201WIRSSS 2022
2301WIRSSS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendations.
Multiple Grants—Federal Funds Accountability and Transparency Act Reporting
Background:
DCF receives federal funding from DHHS for the Refugee Programs and the CCDF Cluster. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community. The CCDF Cluster provides funds to increase availability, affordability, and quality of child care services through subsidizing child care for low-income families, as well as for activities to promote overall child care quality for all children, regardless of subsidy receipt. DCF makes subawards as part of administering both of these grant programs.
Subawards of $30,000 or more are subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DCF identified subawards subject to FFATA reporting requirements using information from DCF’s subaward tracking system. DCF staff provided that information to the Department of Administration’s (DOA’s), Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting
System (FSRS).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we reviewed six subawards we expected to have FFATA submissions during FY 2022-23 for the Refugee Programs and the CCDF Cluster. None of these six subawards were reported in a timely manner in FSRS.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, $6.7 million was provided to subrecipients. Of the $489.9 million DCF expended during FY 2022-23 under the CCDF Cluster, $54.1 million was provided to subrecipients. To determine whether subawards were reported in FSRS in an accurate and timely manner, we reviewed subawards reported in FSRS for two months of FY 2022-23. We interviewed DCF staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Refugee Programs or CCDF Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Refugee Programs or the CCDF Cluster.
Cause:
The query DCF used to identify subawards for FFATA reporting did not identify subawards based on the date the subaward was signed. Instead, the query identified subawards for reporting based on the beginning of the period of performance for the subaward. In addition, DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed, which then excluded those subawards from being identified in the query.
Recommendation:
We recommend the Department of Children and Families review the query used to determine subawards and its overall procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are input and updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-202: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funds Accountability and Transparency Act Reporting
Background:
DCF receives federal funding from DHHS for the Refugee Programs and the CCDF Cluster. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community. The CCDF Cluster provides funds to increase availability, affordability, and quality of child care services through subsidizing child care for low-income families, as well as for activities to promote overall child care quality for all children, regardless of subsidy receipt. DCF makes subawards as part of administering both of these grant programs.
Subawards of $30,000 or more are subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DCF identified subawards subject to FFATA reporting requirements using information from DCF’s subaward tracking system. DCF staff provided that information to the Department of Administration’s (DOA’s), Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting
System (FSRS).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we reviewed six subawards we expected to have FFATA submissions during FY 2022-23 for the Refugee Programs and the CCDF Cluster. None of these six subawards were reported in a timely manner in FSRS.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, $6.7 million was provided to subrecipients. Of the $489.9 million DCF expended during FY 2022-23 under the CCDF Cluster, $54.1 million was provided to subrecipients. To determine whether subawards were reported in FSRS in an accurate and timely manner, we reviewed subawards reported in FSRS for two months of FY 2022-23. We interviewed DCF staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Refugee Programs or CCDF Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Refugee Programs or the CCDF Cluster.
Cause:
The query DCF used to identify subawards for FFATA reporting did not identify subawards based on the date the subaward was signed. Instead, the query identified subawards for reporting based on the beginning of the period of performance for the subaward. In addition, DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed, which then excluded those subawards from being identified in the query.
Recommendation:
We recommend the Department of Children and Families review the query used to determine subawards and its overall procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are input and updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-202: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funds Accountability and Transparency Act Reporting
Background:
DCF receives federal funding from DHHS for the Refugee Programs and the CCDF Cluster. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community. The CCDF Cluster provides funds to increase availability, affordability, and quality of child care services through subsidizing child care for low-income families, as well as for activities to promote overall child care quality for all children, regardless of subsidy receipt. DCF makes subawards as part of administering both of these grant programs.
Subawards of $30,000 or more are subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DCF identified subawards subject to FFATA reporting requirements using information from DCF’s subaward tracking system. DCF staff provided that information to the Department of Administration’s (DOA’s), Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting
System (FSRS).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we reviewed six subawards we expected to have FFATA submissions during FY 2022-23 for the Refugee Programs and the CCDF Cluster. None of these six subawards were reported in a timely manner in FSRS.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, $6.7 million was provided to subrecipients. Of the $489.9 million DCF expended during FY 2022-23 under the CCDF Cluster, $54.1 million was provided to subrecipients. To determine whether subawards were reported in FSRS in an accurate and timely manner, we reviewed subawards reported in FSRS for two months of FY 2022-23. We interviewed DCF staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Refugee Programs or CCDF Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Refugee Programs or the CCDF Cluster.
Cause:
The query DCF used to identify subawards for FFATA reporting did not identify subawards based on the date the subaward was signed. Instead, the query identified subawards for reporting based on the beginning of the period of performance for the subaward. In addition, DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed, which then excluded those subawards from being identified in the query.
Recommendation:
We recommend the Department of Children and Families review the query used to determine subawards and its overall procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are input and updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-202: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Social Services Block Grant—Subrecipient Contracts
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for SSBG. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of the population. During FY 2022-23, DHS provided $9.6 million in SSBG funds to DCF for the children and family aids program, which provides for prevention, investigation, and treatment services related to child abuse and neglect. In addition to general purpose revenue and other federal funds, DCF uses the SSBG funds and contracts with each county for the administration of this program. Because DCF provides funding to counties to carry out the purpose of a federal program, DCF is considered a pass-through entity, and the counties are considered subrecipients.
In establishing contracts, DCF uses specific contract codes within the contract to designate the children and family aids program, the purpose of the program, the costs that will be reimbursed, and the federal programs being used in funding the amount of the contract. The information provided to the subrecipients for each contract code included in the contract, either in the contract or in other referenced information, includes the federal assistance listing number, as appropriate, and other required information. The contract codes for the children and family aids program are then used by the counties when determining which costs may be funded and in requesting reimbursement for costs incurred.
Criteria:
Under 2 CFR s. 200.332, the pass-through entity is required to clearly identify to the subrecipient certain information that allows the subrecipient to understand the federal requirements related to the funding provided. This information includes providing the federal assistance listing number and the amount being provided under the assistance listing number.
Condition:
DCF did not identify in the contracts with the counties that the contract code used for the children and family aids program was partially funding by SSBG. Information such as the assistance listing number and the award amount that was specific to SSBG was not included in the contract or in other information referenced in the contract.
Context:
We reviewed 7 of the 72 county contracts that were entered into during FY 2022-23 and discussed with DCF staff the inclusion of the assistance listing number for the contract codes used for the children and family aids program. During FY 2022-23, DCF subawarded $7.4 million in SSBG funds.
Questioned Costs:
None.
Effect:
Because the contracts with the counties do not include information related to the SSBG program, the counties may be unaware that they have received SSBG funds. This could result in the counties not complying with federal requirements related to SSBG funding.
Cause:
The funds DCF received from DHS were recorded in an appropriation that was designated as program revenue funding. DCF did not have procedures in place to identify the SSBG funds received from DHS for the children and family aids program
as federal funding.
Recommendation:
We recommend the Wisconsin Department of Children and Families:
-inform the counties of any Social Services Block Grant funding provided in subrecipient contracts for the children and family aids program; and
-implement procedures to identify federal funding that is received as a transfer from another state agency when subgranting funds.
Finding 2023-200: Social Services Block Grant—Subrecipient Contracts
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2301WISOSR 2023
2201WISOSR 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendations.
Social Services Block Grant—Subrecipient Contracts
Background:
DHHS provides funding to DHS for the SSBG program. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of the population. In addition, the State can transfer funds received under the Temporary Assistance for Needy Families (TANF) program (Assistance Listing number 93.558) to the SSBG program for use under this program. During FY 2022-23, $14.7 million was transferred to the SSBG program from the TANF program. DHS uses the SSBG funding, including the amounts transferred from the TANF program and general purpose revenue, to provide funding for the community aids program, and more specifically, amounts designated within this program as the “basic county allocation” that can be used by counties to support any eligible service.
DHS contracts with each county for the administration of the community aids program. Because DHS provides funding to counties to carry out the purpose of a federal program, DHS is considered a pass-through entity, and the counties are considered subrecipients. DHS uses its Community Aids Reporting System (CARS) and establishes CARS profiles to designate the program, the purpose of the program, the types of costs that will be reimbursed, and the federal programs that are used in funding the amount of the contract. The information provided to the counties for a CARS profile will include the federal assistance listing number, as appropriate, and other required information. The CARS profile established for the basic county allocation is used by the counties when determining costs that can be funded and in requesting reimbursement for costs incurred.
Criteria:
Under 2 CFR s. 200.332, the pass-through entity is required to clearly identify to the subrecipient certain information that allows the subrecipient to understand the federal requirements related to the funding provided. This information includes providing the federal assistance listing number and the amount being provided under the assistance listing number.
42 USC section 604 allows for the transfer of funds from the TANF program to the SSBG program. Once transferred, the funding is no longer considered TANF funding and is subject to the requirements that apply to the SSBG program. Further, expenditures incurred with the transferred TANF funds would be considered an expenditure of SSBG.
Condition:
In the contracts with the counties, DHS identified that both the SSBG and TANF programs were being used to provide funding for the CARS profile for the basic county allocation. The TANF funds transferred to SSBG are subject to the requirements of the SSBG program, but the information DHS provided to the counties, which included the assistance listing number, inaccurately identified the TANF program as a funding source.
Context:
We reviewed 7 of the 72 county contracts that were executed during FY 2022-23 and discussed with DHS staff the inclusion of the assistance listing number for the CARS profile used for the basic county allocation. During FY 2022-23, DHS expended $33.4 million in SSBG funds, which included transferred TANF funds, and subawarded $32.4 million.
Questioned Costs:
None.
Effect:
Because the contracts with the counties did not accurately identify the transferred TANF funds as those from the SSBG program, the counties were not aware of the full amount of SSBG funds received and as a result may not be aware of the federal requirements related to this funding. This could result in the counties not complying with federal requirements related to the SSBG funding.
Cause:
In contract development, DHS separately identified the SSBG and transferred TANF funds used in funding the basic county allocation. This separation resulted in the error in identifying TANF as a funding source in the contracts with the counties.
Recommendation:
We recommend the Wisconsin Department of Health Services update its procedures for contract development to ensure information provided in its subrecipient contracts identified the Social Services Block Grant as the federal funding source for the basic county allocation of the community aids program related to the transferred Temporary Assistance for Needy Families funds.
Finding 2023-301: Social Services Block Grant—Subrecipient Contracts
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2301WISOSR 2023
2201WISOSR 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Social Services Block Grant—FFATA Reporting
Background:
DHHS provides funding to DHS for the SSBG program. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of the population. In addition to general purpose revenue, DHS uses the SSBG funds for the basic county allocation of the community aids program, and it subawards amounts to each county for the administration of this program. DHS also transfers SSBG funds to the Wisconsin Department of Children and Families (DCF). DCF uses the SSBG funds, in addition to other federal funds and general purpose revenue, for the children and family aids program, and it subawards amounts to each county for the administration of this program.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the SSBG program, DHS has overall responsibility for Federal Funding Accountability and Transparency Act (FFATA) reporting and is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported no later than January 31, 2023.
Condition:
During FY 2022-23, both DHS and DCF made subawards of $30,000 or more in SSBG funds to counties. DHS did not report any SSBG-funded subawards in FSRS.
Context:
During FY 2022-23, DHS expended $33.4 million in SSBG funds of which $32.4 million was provided to subrecipients. During FY 2022-23, DCF expended $9.6 million, of which $7.4 million was provided to subrecipients. We interviewed DHS staff to gain an understanding of the SSBG program, the use of the funds, and procedures for compiling and reviewing subaward information, and submitting this information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the SSBG program. DHS did not comply with FFATA requirements for the reporting of subawards for the SSBG program.
Cause:
For the subgrants provided under the basic county allocation of the community aids program, DHS initially recorded payments of the amounts it subawarded to counties to a general purpose revenue appropriation. As a result, these subawards were not identified in the reports DHS used to determine FFATA reporting. In addition, DHS did not have procedures in place to obtain information related to the subgrants provided by DCF or to determine whether responsibility for FFATA reporting could be delegated to DCF.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-revise its procedures for Federal Funding Accountability and Transparency Act reporting to ensure all subawards funded by federal grants are included in reports used to identify subawards for reporting; and
-develop procedures to identify and report subawards made by the state agencies to which it has transferred federal funding.
Finding 2023-302: Social Services Block Grant—FFATA Reporting
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2301WISOSR 2023
2201WISOSR 2022
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding health care coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced federal medical assistance percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a post-partum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants. DHS also closed certain CHIP and MA cases in the CARES system and continued benefit payments through MMIS.
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under an SCHIP program to participants who did not meet age requirements. At the time participants reached age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, it further stated that changes in circumstances described in 42 s. CFR 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19. Benefits for these participants were maintained either by maintaining eligibility for the participant in the CARES system or by closing the participant’s case in the CARES system and continuing benefit payments for the participant through MMIS.
During our audit, we identified 8,996 SCHIP participants in the CARES system who were age 19 or older as of June 30, 2023. Of these participants, 3,695 were age 19 as of April 30, 2023, 4,578 participants were over age 19 as of April 30, 2023, and 723 participants turned age 19 during May or June 2023.
In a separate analysis, we also identified 1,372 participants who were age 19 or older as of July 1, 2022, who received SCHIP benefits paid through MMIS during FY 2022-23. These participants did not have an open CHIP case in the CARES system for FY 2022-23.
Context:
During FY 2022-23, DHS expended $253.1 million in federal funds under CHIP, including approximately $150.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 81,243 participants identified in the CARES system as an open case in SCHIP between July 2022 and April 2023. From this listing, we identified 8,273 participants who were age 19 or older as of April 30, 2023, and 723 participants who turned age 19 in May and June 2023. We further reviewed detailed FY 2022-23 payments made to managed care organizations and payments made to providers paid on a fee-for-service basis. Using the recipient IDs for the 8,996 participants who were age 19 or older, we calculated total payments to providers identified as costs that were funded by SCHIP.
To identify participants who continued to receive benefits paid directly through MMIS but who did not have an open CHIP case in the CARES system, we reviewed detailed FY 2022-23 payments from MMIS and identified participants who were age 19 or older as of July 1, 2022, who were provided benefits that were identified as being funded by SCHIP. We compared this listing of participants to the listing of participants identified as having an open CHIP case in the CARES system and identified 1,372 participants who were age 19 or older as of July 1, 2022, that were receiving benefits during FY 2022-23 but were not included in the listing of open CHIP cases in the CARES system.
Questioned Costs:
We reviewed detailed FY 2022-23 payment information for the 8,996 SCHIP participants who were age 19 or older, and we identified $16,682,899 in benefits that were provided to them during FY 2022-23. Using the weighted average of the FMAP
in effect for federal fiscal year (FFY) 2022 and FFY 2023 (72.03 percent) and the average temporary increase to the FMAP for FY 2022-23 (4.13 percent), we question $12,706,113, representing the federal share of these payments. We also question an undetermined amount for benefits provided to other ineligible SCHIP participants who continued to receive benefits through MMIS, but were age 19 or older as of July 1, 2022.
Effect:
We identified that DHS made improper payments and received federal reimbursement for participants who were ineligible for SCHIP.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS nor result in system changes to CARES.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. DHS is expected to complete redeterminations of all participants in MA and CHIP by June 2024, which is the end of the unwinding period, and it has stated that CHIP participants who exceeded the age requirement for the program have been prioritized.
Recommendation:
We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate.
Finding 2023-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $12,017,109, Plus an Undetermined Amount
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $689,004, Plus an Undetermined Amount
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees conceptually with the finding, however, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program.
Legislative Audit Bureau Rebuttal: As stated in the finding, and as acknowledged by DHS, DHS maintained continuous eligibility for SCHIP participants who were over age 19. This eligibility requirement continued through the public health emergency. Since CHIP and Medicaid are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the Medicaid program.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding health care coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced federal medical assistance percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a post-partum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants. DHS also closed certain CHIP and MA cases in the CARES system and continued benefit payments through MMIS.
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under an SCHIP program to participants who did not meet age requirements. At the time participants reached age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, it further stated that changes in circumstances described in 42 s. CFR 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19. Benefits for these participants were maintained either by maintaining eligibility for the participant in the CARES system or by closing the participant’s case in the CARES system and continuing benefit payments for the participant through MMIS.
During our audit, we identified 8,996 SCHIP participants in the CARES system who were age 19 or older as of June 30, 2023. Of these participants, 3,695 were age 19 as of April 30, 2023, 4,578 participants were over age 19 as of April 30, 2023, and 723 participants turned age 19 during May or June 2023.
In a separate analysis, we also identified 1,372 participants who were age 19 or older as of July 1, 2022, who received SCHIP benefits paid through MMIS during FY 2022-23. These participants did not have an open CHIP case in the CARES system for FY 2022-23.
Context:
During FY 2022-23, DHS expended $253.1 million in federal funds under CHIP, including approximately $150.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 81,243 participants identified in the CARES system as an open case in SCHIP between July 2022 and April 2023. From this listing, we identified 8,273 participants who were age 19 or older as of April 30, 2023, and 723 participants who turned age 19 in May and June 2023. We further reviewed detailed FY 2022-23 payments made to managed care organizations and payments made to providers paid on a fee-for-service basis. Using the recipient IDs for the 8,996 participants who were age 19 or older, we calculated total payments to providers identified as costs that were funded by SCHIP.
To identify participants who continued to receive benefits paid directly through MMIS but who did not have an open CHIP case in the CARES system, we reviewed detailed FY 2022-23 payments from MMIS and identified participants who were age 19 or older as of July 1, 2022, who were provided benefits that were identified as being funded by SCHIP. We compared this listing of participants to the listing of participants identified as having an open CHIP case in the CARES system and identified 1,372 participants who were age 19 or older as of July 1, 2022, that were receiving benefits during FY 2022-23 but were not included in the listing of open CHIP cases in the CARES system.
Questioned Costs:
We reviewed detailed FY 2022-23 payment information for the 8,996 SCHIP participants who were age 19 or older, and we identified $16,682,899 in benefits that were provided to them during FY 2022-23. Using the weighted average of the FMAP
in effect for federal fiscal year (FFY) 2022 and FFY 2023 (72.03 percent) and the average temporary increase to the FMAP for FY 2022-23 (4.13 percent), we question $12,706,113, representing the federal share of these payments. We also question an undetermined amount for benefits provided to other ineligible SCHIP participants who continued to receive benefits through MMIS, but were age 19 or older as of July 1, 2022.
Effect:
We identified that DHS made improper payments and received federal reimbursement for participants who were ineligible for SCHIP.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS nor result in system changes to CARES.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. DHS is expected to complete redeterminations of all participants in MA and CHIP by June 2024, which is the end of the unwinding period, and it has stated that CHIP participants who exceeded the age requirement for the program have been prioritized.
Recommendation:
We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate.
Finding 2023-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $12,017,109, Plus an Undetermined Amount
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $689,004, Plus an Undetermined Amount
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees conceptually with the finding, however, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program.
Legislative Audit Bureau Rebuttal: As stated in the finding, and as acknowledged by DHS, DHS maintained continuous eligibility for SCHIP participants who were over age 19. This eligibility requirement continued through the public health emergency. Since CHIP and Medicaid are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the Medicaid program.
Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Background:
DHHS provides funding to DHS for the MA Program (Assistance Listing number 93.778). Funding under the MA Program is used to assist states in providing health care services to certain categories of low-income persons. Under the MA Program, a state may obtain a waiver to provide home- and community-based services. Such a waiver may permit an individual to receive services in their own home or community rather than in an institutional care setting. Under 1915 (c) of the Social Security Act, Wisconsin has an approved waiver to administer the Include, Respect, I Self-Direct (IRIS) program. This program provides services to MA-eligible adults that facilitates participant choice, direction, and control over home- and community-based services. The current IRIS waiver approved by CMS is effective from January 1, 2021, through December 31, 2025.
During FY 2022-23, DHS contracted with six independent consulting agencies (ICAs) that assisted IRIS participants in developing individual support and service plans to meet each participant’s needs within the participant’s approved IRIS annual budget. DHS also contracted with four fiscal employer agents (FEAs) that are responsible for receiving invoices for services provided to participants, reviewing the invoices in accordance with the approved individual support and service plan, and for paying the invoice, when it is aligned with the approved plan. The FEA submits information to DHS related to the approved payments, and DHS makes funds available to enable the FEA to make the payments. On a monthly basis, the FEA is also required to submit through the DHS Encounter system participant-specific data of the detailed services provided.
Criteria:
As required by 42 CFR Part 441.303 (b), the approved waiver for the IRIS program outlines several financial integrity and accountability oversight activities to be performed by DHS. These oversight activities provide assurances related to the financial integrity and accountability of funds expended for home- and community-based services under the IRIS program. Under 42 CFR Part 441.302 and 441.302 (b), CMS may terminate an already granted waiver if an agency does not assure the financial accountability of funds expended for home- and community-based services.
Condition:
Based upon our review of selected financial integrity and accountability oversight activities included in the approved waiver, we found that DHS performed some but not all of the oversight activities. For example, DHS required each ICA and FEA to have an annual independent third-party financial audit performed, which DHS was to obtain and review. However, we identified that during FY 2022-23 DHS had not performed certain financial integrity and accountability oversight activities outlined in the approved waiver, including:
-completing an audit of 20 percent of the claims exceeding $2,500 or more that were received in biweekly claims files submitted for payment from the FEA; and
-completing a data integrity audit to review the detailed participant data submitted by the FEAs through the DHS Encounter system, including reviewing this data for accuracy and compliance with claim submission standards and source data authorizations, such as the service provided, the frequency of services, the authorization period, and the date of service.
Context:
During FY 2022-23, DHS provided $8.1 billion in benefit payments to participants in the MA Program. Payments for care or services provided to IRIS participants was $585.1 million of this amount. We reviewed the IRIS waiver to identify the financial integrity and accountability oversight activities DHS staff stated that they would perform to provide the required assurances. For selected financial integrity and accountability oversight activities outlined within the waiver, we conducted inquiries of DHS staff to determine if these activities had been performed.
Questioned Costs:
None.
Effect:
DHS did not comply with all financial integrity and accountability oversight activities included in the approved waiver and, therefore, did not have the assurance that these oversight activities could provide. In addition, because DHS did not perform all financial integrity and accountability oversight activities, it is at risk for the waiver to be terminated.
Cause:
DHS did not have procedures in place to perform the financial integrity and accountability oversight activities included in the approved waiver. DHS reported that in a prior year it had performed an assessment of the amount of work required
to complete the oversight activities included in the approved waiver and determined it would be infeasible. However, DHS did not take steps to document alternative oversight activities that would meet the objective to provide financial integrity and accountability oversight or seek an amendment to the waiver.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-implement the financial integrity and accountability oversight activities in its approved waiver; or
-determine if alternative oversight activities that meet the objective to provide financial integrity and accountability oversight can be performed; and
-work with the federal government to determine whether an amendment to its current waiver is needed.
Finding 2023-303: Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2305WI5MAP 2023
Questioned Costs: None
COVID-19—Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2205WI5MAP 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Background:
DHHS provides funding to DHS for the MA Program (Assistance Listing number 93.778). Funding under the MA Program is used to assist states in providing health care services to certain categories of low-income persons. Under the MA Program, a state may obtain a waiver to provide home- and community-based services. Such a waiver may permit an individual to receive services in their own home or community rather than in an institutional care setting. Under 1915 (c) of the Social Security Act, Wisconsin has an approved waiver to administer the Include, Respect, I Self-Direct (IRIS) program. This program provides services to MA-eligible adults that facilitates participant choice, direction, and control over home- and community-based services. The current IRIS waiver approved by CMS is effective from January 1, 2021, through December 31, 2025.
During FY 2022-23, DHS contracted with six independent consulting agencies (ICAs) that assisted IRIS participants in developing individual support and service plans to meet each participant’s needs within the participant’s approved IRIS annual budget. DHS also contracted with four fiscal employer agents (FEAs) that are responsible for receiving invoices for services provided to participants, reviewing the invoices in accordance with the approved individual support and service plan, and for paying the invoice, when it is aligned with the approved plan. The FEA submits information to DHS related to the approved payments, and DHS makes funds available to enable the FEA to make the payments. On a monthly basis, the FEA is also required to submit through the DHS Encounter system participant-specific data of the detailed services provided.
Criteria:
As required by 42 CFR Part 441.303 (b), the approved waiver for the IRIS program outlines several financial integrity and accountability oversight activities to be performed by DHS. These oversight activities provide assurances related to the financial integrity and accountability of funds expended for home- and community-based services under the IRIS program. Under 42 CFR Part 441.302 and 441.302 (b), CMS may terminate an already granted waiver if an agency does not assure the financial accountability of funds expended for home- and community-based services.
Condition:
Based upon our review of selected financial integrity and accountability oversight activities included in the approved waiver, we found that DHS performed some but not all of the oversight activities. For example, DHS required each ICA and FEA to have an annual independent third-party financial audit performed, which DHS was to obtain and review. However, we identified that during FY 2022-23 DHS had not performed certain financial integrity and accountability oversight activities outlined in the approved waiver, including:
-completing an audit of 20 percent of the claims exceeding $2,500 or more that were received in biweekly claims files submitted for payment from the FEA; and
-completing a data integrity audit to review the detailed participant data submitted by the FEAs through the DHS Encounter system, including reviewing this data for accuracy and compliance with claim submission standards and source data authorizations, such as the service provided, the frequency of services, the authorization period, and the date of service.
Context:
During FY 2022-23, DHS provided $8.1 billion in benefit payments to participants in the MA Program. Payments for care or services provided to IRIS participants was $585.1 million of this amount. We reviewed the IRIS waiver to identify the financial integrity and accountability oversight activities DHS staff stated that they would perform to provide the required assurances. For selected financial integrity and accountability oversight activities outlined within the waiver, we conducted inquiries of DHS staff to determine if these activities had been performed.
Questioned Costs:
None.
Effect:
DHS did not comply with all financial integrity and accountability oversight activities included in the approved waiver and, therefore, did not have the assurance that these oversight activities could provide. In addition, because DHS did not perform all financial integrity and accountability oversight activities, it is at risk for the waiver to be terminated.
Cause:
DHS did not have procedures in place to perform the financial integrity and accountability oversight activities included in the approved waiver. DHS reported that in a prior year it had performed an assessment of the amount of work required
to complete the oversight activities included in the approved waiver and determined it would be infeasible. However, DHS did not take steps to document alternative oversight activities that would meet the objective to provide financial integrity and accountability oversight or seek an amendment to the waiver.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-implement the financial integrity and accountability oversight activities in its approved waiver; or
-determine if alternative oversight activities that meet the objective to provide financial integrity and accountability oversight can be performed; and
-work with the federal government to determine whether an amendment to its current waiver is needed.
Finding 2023-303: Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2305WI5MAP 2023
Questioned Costs: None
COVID-19—Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2205WI5MAP 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Housing and Urban Development (HUD) provides funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the CDBG program. The U.S. Department of Health and Human Services provides funding to DOA for LIHWAP. The CDBG program is intended to provide housing and expanded economic opportunities mainly for low- to moderate-income persons. LIHWAP provides financial assistance to low-income households for drinking water and wastewater service expenses.
CDBG and LIHWAP subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, program staff in DEHCR were responsible for tracking grant awards and providing that information to the Bureau of Financial Management, which reviewed and summarized the award information and reported the information to DOA’s Division of Executive Budget and Finance (DEBF). DEBF was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS). Beginning in March 2023, and in response to an audit finding related to FFATA reporting from our FY 2021-22 audit (report 23-4), DOA made changes in its FFATA reporting procedures.
Criteria:
Under 2 CFR s. 170, DOA is required to report subawards of $30,000 or more in FSRS, including any amendments or modifications to a subaward. This reporting must occur no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 9 of the 27 CDBG subawards DOA indicated were signed in FY 2022-23. Only one of the nine subawards selected for testing was reported in FSRS in a timely manner. One subaward that was made in June 2023 had not been reported in FSRS as of the time of our fieldwork in January 2024.
In addition, we reviewed the monthly spreadsheets DEHCR used to track subawards required to be reported in FSRS. To assess the accuracy and timeliness of reporting in FSRS, we selected 7 of the 72 subaward changes that were on the monthly spreadsheets in FY 2022-23. Although the original subawards were dated from July 2018 through June 2021, we found that DOA had entered into FSRS the original subaward for each of the seven sampled items in the period from February through May 2023. Further, four of the seven subaward amendments that required an update in FSRS had not been updated as of our fieldwork in January 2024.
Finally, for LIHWAP, DOA provided funding to one subrecipient. DOA entered into a subaward agreement for $500,000 with the subrecipient in November 2021. DOA amended the agreement in September 2022 to provide an additional $500,000, and again in March 2023 to provide an additional $250,000. However, DOA did not report the subaward or the amendments in FSRS until March 2023.
Context:
Of the $82.0 million DOA expended under the CDBG program during FY 2022-23, $80.9 million was provided to subrecipients. Of the $16.5 million DOA expended under LIHWAP during FY 2022-23, $0.6 million was provided to subrecipients. We interviewed DOA staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for reporting the information in FSRS. We requested subaward agreements and amendments, tracking spreadsheets, and reporting information from FSRS for each subaward to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the CDBG program and LIHWAP. DOA did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the CDBG program and LIHWAP.
Cause:
DOA staff indicated that one employee was responsible for the management of contracts for federal programs within DEHCR during the public health emergency. Due to the volume of federal funding being managed, DOA indicated it did not prioritize FFATA reporting.
In addition, one of the subawards that was not reported for the CDBG program was a subaward funded by program income. DOA did not believe that subawards funded with program income were required to be reported in FSRS. However, officials with HUD communicated to us in writing that subawards either partially or fully funded by program income are required to be reported in FSRS.
Finally, we note that we reported a finding related to FFATA reporting for the Low-Income Home Energy Assistance Program during our FY 2021-22 audit (report 23-4). DOA indicated that at the time we reported these concerns in February 2023, it had taken steps to review subaward agreements and amendments going back several years and to update FSRS.
Recommendation:
We recommend the Wisconsin Department of Administration:
- review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in FSRS in a timely manner; and
- develop and implement procedures to ensure subawards funded by program income for the Community Development Block Grant program are reported in the FFATA Subaward Reporting System accurately and in a timely manner or document why the subaward was exempt from FFATA reporting.
Finding 2023-100: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-DC-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Housing and Urban Development (HUD) provides funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the CDBG program. The U.S. Department of Health and Human Services provides funding to DOA for LIHWAP. The CDBG program is intended to provide housing and expanded economic opportunities mainly for low- to moderate-income persons. LIHWAP provides financial assistance to low-income households for drinking water and wastewater service expenses.
CDBG and LIHWAP subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, program staff in DEHCR were responsible for tracking grant awards and providing that information to the Bureau of Financial Management, which reviewed and summarized the award information and reported the information to DOA’s Division of Executive Budget and Finance (DEBF). DEBF was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS). Beginning in March 2023, and in response to an audit finding related to FFATA reporting from our FY 2021-22 audit (report 23-4), DOA made changes in its FFATA reporting procedures.
Criteria:
Under 2 CFR s. 170, DOA is required to report subawards of $30,000 or more in FSRS, including any amendments or modifications to a subaward. This reporting must occur no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 9 of the 27 CDBG subawards DOA indicated were signed in FY 2022-23. Only one of the nine subawards selected for testing was reported in FSRS in a timely manner. One subaward that was made in June 2023 had not been reported in FSRS as of the time of our fieldwork in January 2024.
In addition, we reviewed the monthly spreadsheets DEHCR used to track subawards required to be reported in FSRS. To assess the accuracy and timeliness of reporting in FSRS, we selected 7 of the 72 subaward changes that were on the monthly spreadsheets in FY 2022-23. Although the original subawards were dated from July 2018 through June 2021, we found that DOA had entered into FSRS the original subaward for each of the seven sampled items in the period from February through May 2023. Further, four of the seven subaward amendments that required an update in FSRS had not been updated as of our fieldwork in January 2024.
Finally, for LIHWAP, DOA provided funding to one subrecipient. DOA entered into a subaward agreement for $500,000 with the subrecipient in November 2021. DOA amended the agreement in September 2022 to provide an additional $500,000, and again in March 2023 to provide an additional $250,000. However, DOA did not report the subaward or the amendments in FSRS until March 2023.
Context:
Of the $82.0 million DOA expended under the CDBG program during FY 2022-23, $80.9 million was provided to subrecipients. Of the $16.5 million DOA expended under LIHWAP during FY 2022-23, $0.6 million was provided to subrecipients. We interviewed DOA staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for reporting the information in FSRS. We requested subaward agreements and amendments, tracking spreadsheets, and reporting information from FSRS for each subaward to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the CDBG program and LIHWAP. DOA did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the CDBG program and LIHWAP.
Cause:
DOA staff indicated that one employee was responsible for the management of contracts for federal programs within DEHCR during the public health emergency. Due to the volume of federal funding being managed, DOA indicated it did not prioritize FFATA reporting.
In addition, one of the subawards that was not reported for the CDBG program was a subaward funded by program income. DOA did not believe that subawards funded with program income were required to be reported in FSRS. However, officials with HUD communicated to us in writing that subawards either partially or fully funded by program income are required to be reported in FSRS.
Finally, we note that we reported a finding related to FFATA reporting for the Low-Income Home Energy Assistance Program during our FY 2021-22 audit (report 23-4). DOA indicated that at the time we reported these concerns in February 2023, it had taken steps to review subaward agreements and amendments going back several years and to update FSRS.
Recommendation:
We recommend the Wisconsin Department of Administration:
- review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in FSRS in a timely manner; and
- develop and implement procedures to ensure subawards funded by program income for the Community Development Block Grant program are reported in the FFATA Subaward Reporting System accurately and in a timely manner or document why the subaward was exempt from FFATA reporting.
Finding 2023-100: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-DC-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Crime Victim Assistance—Federal Funding Accountability and Transparency Act Reporting
Background:
DOJ receives federal funding from the U.S. Department of Justice for the Crime Victim Assistance program. The Crime Victim Assistance program provides funding to support direct services to victims of violent crime. DOJ subawards funds as part of administering this program.
Subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DOJ identified subawards subject to FFATA reporting using information from its grants administration system. DOJ staff provided that information to DOA’s Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DOJ is required to report in FSRS subawards of $30,000 or more under the Crime Victim Assistance program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 15 of 109 subawards DOJ made during FY 2022-23 under the Crime Victim Assistance program. None of the subawards we selected were reported in a timely manner in FSRS, including seven subawards that were reported one month late, seven subawards that were reported three or more months late, and one subaward that was not located in FSRS.
Context:
Of the $37.5 million DOJ expended under the Crime Victim Assistance program during FY 2022-23, $36.3 million was provided to subrecipients. We interviewed DOJ staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DOJ did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Crime Victim Assistance program. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Crime Victim Assistance program.
Cause:
DOJ did not provide FFATA reporting information to DOA in a timely manner. For the award that could not be located in FSRS, DOJ staff indicated that DOJ’s initial submission to DOA did not include the correct subrecipient identifier to report in FSRS. DOJ corrected this error in January 2023 and resubmitted the FFATA reporting information to DOA, which acknowledged receipt of the resubmitted information. DOJ did not determine why the corrected information was not in FSRS.
Recommendation:
We recommend the Wisconsin Department of Justice review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-900: Crime Victim Assistance—Federal Funding Accountability and Transparency Act Reporting
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Justice: The Wisconsin Department of Justice agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Labor provides funding to DWD for the WIOA Cluster, which includes the WIOA Adult Program, the WIOA Youth Activities program, and the WIOA Dislocated Worker Formula Grants program. This cluster is intended to provide a framework for delivery of workforce activities at the state and local levels to help job seekers access employment, education, training, and support services to succeed in the labor market. DWD subgrants funds under each program in the WIOA Cluster to local workforce development boards, and federal regulations allow for the transfer of funds between the WIOA Adult Program and WIOA Dislocated Worker Formula Grants program.
For the WIOA Cluster, subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DWD accountants were responsible for summarizing grant award information and providing that information to DOA for uploading into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DWD is required to report in FSRS subawards of $30,000 or more under each WIOA program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 27 subawards that were awarded by DWD under the WIOA Cluster during FY 2022-23, including original subawards and amendments to these subawards. We found that 2 of the 27 subawards selected for testing were not reported in FSRS in a timely manner. Although these two subawards were awarded in May 2023, they were not entered into FSRS at the time of our fieldwork in February 2024.
For the remaining 25 subawards, the date the subaward agreement was signed was reported incorrectly. Rather than reporting the date the subaward agreement was signed, DWD reported the date the subaward period began. This date was used incorrectly as the date the subaward agreement was signed for the initial subaward and for any amendments to a subaward.
Context:
Of the $31.7 million DWD expended under the WIOA Cluster during FY 2022-23, $23.9 million was provided to subrecipients. We interviewed DWD staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DWD did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS for the WIOA Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the WIOA Cluster.
Cause:
DWD staff indicated that a single employee was responsible for obtaining and summarizing data used in FFATA reporting for the WIOA Cluster, and no additional oversight or review was performed.
For the two subawards that were not reported, DWD staff indicated that these were transfers of award amounts between different WIOA programs. DWD was not aware that reporting is separate for each WIOA program subaward in FFATA and that these transfers were required to be reported.
Recommendation:
We recommend the Wisconsin Department of Workforce Development implement procedures for review and oversight of its Federal Funding Accountability and Transparency Act reporting to ensure all required subawards of $30,000 or more, including amendments or modifications, are identified and submitted in a timely manner and accurate award information, including the date the subaward agreement was signed, is reported.
Finding 2023-600: WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Workforce Development: The Wisconsin Department of Workforce Development agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Labor provides funding to DWD for the WIOA Cluster, which includes the WIOA Adult Program, the WIOA Youth Activities program, and the WIOA Dislocated Worker Formula Grants program. This cluster is intended to provide a framework for delivery of workforce activities at the state and local levels to help job seekers access employment, education, training, and support services to succeed in the labor market. DWD subgrants funds under each program in the WIOA Cluster to local workforce development boards, and federal regulations allow for the transfer of funds between the WIOA Adult Program and WIOA Dislocated Worker Formula Grants program.
For the WIOA Cluster, subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DWD accountants were responsible for summarizing grant award information and providing that information to DOA for uploading into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DWD is required to report in FSRS subawards of $30,000 or more under each WIOA program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 27 subawards that were awarded by DWD under the WIOA Cluster during FY 2022-23, including original subawards and amendments to these subawards. We found that 2 of the 27 subawards selected for testing were not reported in FSRS in a timely manner. Although these two subawards were awarded in May 2023, they were not entered into FSRS at the time of our fieldwork in February 2024.
For the remaining 25 subawards, the date the subaward agreement was signed was reported incorrectly. Rather than reporting the date the subaward agreement was signed, DWD reported the date the subaward period began. This date was used incorrectly as the date the subaward agreement was signed for the initial subaward and for any amendments to a subaward.
Context:
Of the $31.7 million DWD expended under the WIOA Cluster during FY 2022-23, $23.9 million was provided to subrecipients. We interviewed DWD staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DWD did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS for the WIOA Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the WIOA Cluster.
Cause:
DWD staff indicated that a single employee was responsible for obtaining and summarizing data used in FFATA reporting for the WIOA Cluster, and no additional oversight or review was performed.
For the two subawards that were not reported, DWD staff indicated that these were transfers of award amounts between different WIOA programs. DWD was not aware that reporting is separate for each WIOA program subaward in FFATA and that these transfers were required to be reported.
Recommendation:
We recommend the Wisconsin Department of Workforce Development implement procedures for review and oversight of its Federal Funding Accountability and Transparency Act reporting to ensure all required subawards of $30,000 or more, including amendments or modifications, are identified and submitted in a timely manner and accurate award information, including the date the subaward agreement was signed, is reported.
Finding 2023-600: WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Workforce Development: The Wisconsin Department of Workforce Development agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Labor provides funding to DWD for the WIOA Cluster, which includes the WIOA Adult Program, the WIOA Youth Activities program, and the WIOA Dislocated Worker Formula Grants program. This cluster is intended to provide a framework for delivery of workforce activities at the state and local levels to help job seekers access employment, education, training, and support services to succeed in the labor market. DWD subgrants funds under each program in the WIOA Cluster to local workforce development boards, and federal regulations allow for the transfer of funds between the WIOA Adult Program and WIOA Dislocated Worker Formula Grants program.
For the WIOA Cluster, subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DWD accountants were responsible for summarizing grant award information and providing that information to DOA for uploading into the FFATA Subaward Reporting System (FSRS).
Criteria:
Under 2 CFR s. 170, DWD is required to report in FSRS subawards of $30,000 or more under each WIOA program, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Several key data elements are required to be reported in FSRS, including information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 27 subawards that were awarded by DWD under the WIOA Cluster during FY 2022-23, including original subawards and amendments to these subawards. We found that 2 of the 27 subawards selected for testing were not reported in FSRS in a timely manner. Although these two subawards were awarded in May 2023, they were not entered into FSRS at the time of our fieldwork in February 2024.
For the remaining 25 subawards, the date the subaward agreement was signed was reported incorrectly. Rather than reporting the date the subaward agreement was signed, DWD reported the date the subaward period began. This date was used incorrectly as the date the subaward agreement was signed for the initial subaward and for any amendments to a subaward.
Context:
Of the $31.7 million DWD expended under the WIOA Cluster during FY 2022-23, $23.9 million was provided to subrecipients. We interviewed DWD staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
DWD did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS for the WIOA Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the WIOA Cluster.
Cause:
DWD staff indicated that a single employee was responsible for obtaining and summarizing data used in FFATA reporting for the WIOA Cluster, and no additional oversight or review was performed.
For the two subawards that were not reported, DWD staff indicated that these were transfers of award amounts between different WIOA programs. DWD was not aware that reporting is separate for each WIOA program subaward in FFATA and that these transfers were required to be reported.
Recommendation:
We recommend the Wisconsin Department of Workforce Development implement procedures for review and oversight of its Federal Funding Accountability and Transparency Act reporting to ensure all required subawards of $30,000 or more, including amendments or modifications, are identified and submitted in a timely manner and accurate award information, including the date the subaward agreement was signed, is reported.
Finding 2023-600: WIOA Cluster—Federal Funding Accountability and Transparency Act Reporting
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Workforce Development: The Wisconsin Department of Workforce Development agrees with the audit finding and recommendation.
Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments
Background:
The ERA Program was established in FY 2020-21 under the federal Consolidated Appropriations Act of 2021 and continued in FY 2021-22 and FY 2022-23 under ARPA. Treasury provided funding to DEHCR for the ERA Program. The program
was established to assist households that are unable to pay rent or utilities. DOA established the Wisconsin Emergency Rental Assistance (WERA) program using the federal ERA Program funding.
To administer the WERA program, DOA contracted with community action agencies and Energy Services, Inc. (ESI) to intake and review applications for eligibility. The community action agencies and ESI were responsible for entering the applications into DOA’s Home Energy (HE) Plus computer system, which was used to determine and process the benefit payment amount.
In both our performance evaluation of the ERA Program and Emergency Solutions Grant Program (report 22-3) and in our FY 2020-21 single audit (report 22-5), we identified concerns with DOA’s administration of the WERA program. We also identified continued concerns as part of our FY 2021-22 single audit (report 23-4) and recommended that DOA make improvements (Finding 2022-102 in report 23-4). In its response to our recommendations, DOA updated its policies and procedures in the WERA Program Manual and provided training to the community action agencies and ESI.
Criteria:
To be eligible for DOA’s WERA program, under Treasury guidance a household must be obligated to pay rent on a residential dwelling and:
-at least one individual within the household must qualify for unemployment benefits or experience a reduction in household income, incur significant costs, or experience other financial hardship because of the public health emergency; and
-at least one individual within the household must be at risk of experiencing homelessness or housing instability; and
-the household must be a low-income family as defined in 42 USC 1437a (b).
Treasury guidance allows the State to rely on self-attestation for verification of an applicant’s income. If a household meets the eligibility requirements based on a written attestation without further documentation, Treasury guidance indicates the State must redetermine household income every three months by requesting that applicants submit documentation or a written attestation.
Treasury guidance indicates that applicants must provide a current lease that is signed by the applicant and the landlord identifying the rental unit and the rental payment amount. If a lease is unavailable and the applicant cannot present documentation of the rental amount, Treasury guidance indicates that a written attestation may be accepted for up to three months. If additional assistance is needed after that time, documentation of the rental amount is required.
To make benefit payments under the WERA program, DOA requires:
-an income attestation form, which indicates that the applicant has been unable to pay rent and/or utilities and is at risk of losing housing or facing eviction, states that the applicant is not receiving other federally funded emergency rental assistance, and describes why income was affected;
-a renter verification form, which indicates the applicant’s name and applicant’s rental information, such as landlord, rental amount, and description of assistance requested; and
-supporting documentation, such as invoices, a lease agreement, or other documentation.
Further, when recertifying an applicant for eligibility after three months, DOA’s WERA Program Manual indicates that the applicant’s current income must be reviewed, notes are required to be entered into HE Plus indicating how the income eligibility was calculated, and an updated renter verification form is to be uploaded into HE Plus.
Condition:
We tested a random sample of 60 applicants who applied for and received benefits under the WERA program. In our testing, we found that DOA did not have sufficient documentation in HE Plus to demonstrate that four of the applicants were eligible to receive benefits under the program or that the costs were allowable under the ERA Program. We found concerns with:
-the income attestation form for 1 of 60 applicants in our sample where DOA did not have documentation in HE Plus of a completed income attestation form;
-the income recertification documentation for 2 of 60 applicants in our sample where DOA did not have documentation in HE Plus that a timely income recertification was completed; and
-the renter verification form for 1 of 60 applicants in our sample where DOA did not have documentation in HE Plus of a completed renter verification form.
Context:
Of the $98.9 million in ERA Program benefit payments DOA processed using HE Plus in FY 2022-23, $87.5 million was made to either landlords or tenants. A total of 25,201 applicants were reported in HE Plus as having received rental assistance
benefit payments under the ERA Program in FY 2022-23.
We evaluated Treasury guidance related to the ERA Program, discussed the application procedures with DOA staff, and reviewed DOA’s WERA Program Manual. We selected a random sample of 60 applicants who received ERA Program benefits in FY 2022-23 and reviewed the available documentation in HE Plus.
Questioned Costs:
We question $15,056 in rental assistance payments for the four applicants we identified for whom DOA did not have adequate supporting documentation in HE Plus. We determined that questioned costs include:
-$4,400 in benefits paid for one applicant for whom DOA did not have documentation in HE Plus of a completed income attestation form;
-$9,571 in benefits paid for two applicants for whom DOA did not have documentation in HE Plus of a timely income recertification; and
-$1,085 in benefits paid for one applicant for whom DOA did not have documentation in HE Plus of a renter verification form.
We also question an undetermined amount for applicants that we did not test.
Effect:
DOA provided rental and utility assistance to applicants who may have been ineligible to receive ERA Program benefits, which may have resulted in improper payments.
Cause:
During FY 2022-23, DOA did not provide adequate management oversight of ESI and the community action agencies that were responsible for entering the applicant information into HE Plus to ensure the appropriate supporting documentation was entered into the system. Supporting documentation was either not obtained or not included in HE Plus by the community action agencies or ESI.
Recommendation:
We recommend the Wisconsin Department of Administration:
-obtain the required documentation for the four applicants we identified or seek to recoup improper benefit payments it made to these applicants; and
-provide additional training and technical assistance to the community action agencies and Energy Services, Inc. (ESI) on the adequacy of supporting documentation that is to be obtained and entered into Home Energy (HE) Plus by the community action agencies and ESI.
Finding 2023-102: Emergency Rental Assistance Program—Documentation to Support Applicant Eligibility and Benefit Payments
COVID-19—Emergency Rental Assistance Program
(Assistance Listing number 21.023)
Award Number Award Year
None 2021
Questioned Costs: $15,056, Plus an Undetermined Amount
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Emergency Rental Assistance Program—Subrecipient Monitoring
Background:
The ERA Program was established in FY 2020-21 under the federal Consolidated Appropriations Act of 2021 and continued in FY 2021-22 and FY 2022-23 under ARPA. Treasury provided funding to DEHCR for the ERA Program. The program was established to assist households that are unable to pay rent or utilities. DOA established the WERA program using the federal ERA Program funding.
To administer the WERA program, DOA contracted with community action agencies and ESI to intake and review applications for eligibility. The community action agencies and ESI were responsible for entering the applications into DOA’s HE Plus computer system, which was used to determine and process the benefit payment amounts.
Criteria:
Section 2 CFR s. 200.332 (d) through (f) requires DOA to monitor the activities of the community action agencies and ESI as necessary to ensure that the community action agencies and ESI use the subaward for authorized purposes, take timely and appropriate action on all deficiencies detected through monitoring, and comply with the terms and conditions of the subaward.
DOA’s policies and procedures for monitoring the community action agencies and ESI under the WERA program require DOA staff to review approximately four percent of all WERA applications weekly to assess that the documentation is accurate and complete, and that the applicants are eligible. DOA staff are required to outreach to the staff at the community action agencies or ESI to resolve any omission or error. The community action agencies or ESI is required to take corrective action, which may include obtaining documentation and adding it to HE Plus within seven to ten business days.
Condition:
During FY 2022-23, DOA did not perform all monitoring required by federal regulations or its policies and procedures. We found that DOA did not complete monitoring of the community action agencies between February 2023 and June 2023. Further, DOA only completed monitoring of ESI during the months of January 2023 and June 2023.
For the monitoring DOA did complete in FY 2022-23, we reviewed the documentation for seven of the weeks and found that DOA staff identified 69 applications where the community action agency or ESI did not include sufficient documentation in HE Plus to demonstrate that the applicant was eligible to receive benefits under the program or that the costs were allowable to be funded by the WERA program.
We reviewed 21 of the 69 applications for which DOA had identified documentation concerns and found that 16 of the 21 had not been resolved in HE Plus at the time of our fieldwork in February 2024. The documentation concerns were identified in DOA’s monitoring reviews, which took place in August 2022, October 2022, and January 2023. When we requested documentation of DOA’s communications with the community action agencies or ESI, DOA staff told us they did not communicate the results of the reviews to the community action agencies or ESI.
Context:
In FY 2022-23, DOA processed $98.9 million in ERA Program benefit payments using HE Plus. A total of 25,201 applicants were reported in HE Plus as having received benefit payments under the ERA Program in FY 2022-23.
We reviewed and discussed DOA’s procedures for tracking and completing monitoring for the community action agencies and ESI. We also evaluated the monitoring completed in FY 2022-23. We selected 21 of the 69 applications for which DOA’s weekly monitoring identified documentation concerns, missing signatures, or other errors and for which the applicant received ERA Program benefits in FY 2022 23. We reviewed available documentation related to these applications in HE Plus.
Questioned Costs:
We question an undetermined amount for individuals that DOA identified in their monitoring of the community action agencies or ESI that did not have sufficient documentation in HE Plus.
Effect:
Because DOA did not ensure the community action agencies and ESI were taking timely and appropriate action on the deficiencies detected through monitoring for the ERA Program, there is a higher risk that DOA, ESI, and the community action agencies are not in compliance with all federal requirements. In addition, DOA provided rental assistance to applicants who may have been ineligible to receive ERA Program benefits, which may have resulted in improper payments.
Cause:
DOA staff indicated that monitoring of ESI was inadvertently missed. In addition, DOA indicated that monitoring was temporarily stopped between February 2023 and June 2023 because of a temporary pause in accepting new WERA applications in HE Plus as ESI and community action agencies processed a backlog of existing WERA applications. However, the processing of backlogged applications created new applications in HE Plus that required monitoring. In addition, DOA did not have adequate management oversight to ensure its established monitoring procedures were being followed. DOA noted that there was no procedure in place for management oversight of the monitoring program in FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Administration:
-review its existing monitoring procedures and ensure adequate management oversight procedures are established, documented, and followed;
-complete review and follow-up with the community action agencies or Energy Services, Inc. (ESI) identified by its existing monitoring procedures; and
-consider if additional monitoring should be completed for the community action agencies or ESI for the months during FY 2022-23 when the Department of Administration paused monitoring for the Emergency Rental Assistance Program.
Finding 2023-103: Emergency Rental Assistance Program—Subrecipient Monitoring
COVID-19—Emergency Rental Assistance Program (Assistance Listing number 21.023)
Award Number Award Year
None 2021
Questioned Costs: Undetermined
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Homeowner Assistance Fund—Service Organization Internal Controls
Background:
Under the American Rescue Plan Act (ARPA) of 2021, the U.S. Department of the Treasury (Treasury) provided funding to DOA’s DEHCR for HAF. This program was established to mitigate financial hardships associated with the public health emergency, including for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, losses of utilities or home energy services, and displacements of homeowners experiencing financial hardship after January 21, 2020.
Criteria:
Under 2 CFR 200.303, DOA is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the award terms and conditions. This includes instances in which management contracts with a service organization, which is an organization that provides services to another entity and whose services are relevant to the entity’s internal controls. For example, DOA contracted with a service organization to host and maintain a computer system to assist in determining the eligibility of individuals applying for HAF benefits, approving these benefits, storing information on HAF applicants, and for reporting HAF activities to the federal government.
When using a service organization, the entity should gain assurances that the internal controls at the service organization are operating effectively because weaknesses in the service organization’s internal controls could affect the activity of the entity. Such assurances could be gained through a service organization audit, which includes a report on the service organization’s internal controls by an independent auditor. One type of audit that may be completed includes an opinion on the fairness of management’s description of the internal controls in place at the service organization, whether the auditor believes the service organization’s internal controls are suitably designed to achieve the internal control objectives, and whether the service organization’s internal controls are effective at achieving the internal control objectives. In addition, an entity relying on a service organization audit report should review the complementary user entity controls referenced in the report and ensure these controls or others are in place at the entity.
If an entity relying on a service organization does not obtain a service organization audit report, the entity should ensure it has assessed the work being completed by the service organization, and has implemented procedures to ensure both the accuracy of processing completed by the service organization and the information provided by the service organization.
Condition:
DEHCR did not proactively obtain a service organization audit report from its service organization for HAF, nor did it perform other procedures sufficient to assess and reduce risk. In June 2023, DEHCR provided us with a June 2022 service organization audit report that covered the period November 25, 2021, to May 31, 2022. Since this report did not test whether the service organization’s internal controls were operating effectively for FY 2022-23, in October 2023 we asked DEHCR to provide us with the subsequent service organization audit report. In response to our additional inquiries, DEHCR contacted the service organization to obtain the report. In November 2023, DEHCR provided us with the September 2023 service organization audit report, which tested whether internal controls of the service organization were operating effectively for the period June 1, 2022, to May 31, 2023.
DECHR did not provide documentation to evidence that it had reviewed the June 2022 or September 2023 service organization audit reports. DEHCR staff indicated they reviewed the service organization audit reports and contacted the service organization in December 2023 to discuss the findings presented in the September 2023 report after we had requested the report. In January 2024, DEHCR staff indicated they had not documented their review and assessment of either the June 2022 or September 2023 service organization audit reports. DEHCR also did not provide documentation to evidence that it had reviewed the complementary user entity controls that are important for DEHCR to have in place in order to rely on the service organization audit report.
Context:
During FY 2022-23, DOA expended $47.8 million in HAF funding. DOA reported that $43.9 million, or 91.8 percent, of the expenditures were benefit payments to various entities, including mortgage and utility companies, on behalf of individuals who had their eligibility determinations processed by the computer system maintained by DOA’s service organization. We reviewed and discussed with DEHCR its procedures for determining eligibility for HAF, including its reliance on the computer system maintained by the service organization.
Questioned Costs:
None.
Effect:
DOA and the federal government cannot be assured that the service organization controls are effective in determining eligibility or completing federal reporting for HAF.
Cause:
DOA did not have sufficient procedures in place to obtain the service organization audit report from its service organization for HAF nor to use the service organization audit report as a tool to assess effectiveness of the internal controls for the computer system maintained by the service organization. While DOA’s contract with the service organization required the service organization to have an annual independent audit completed, the service organization was required to provide the service organization audit report to DOA upon request. In addition, DOA did not have sufficient procedures to ensure DEHCR reviewed that the complementary user entity controls referenced in the service organization audit report are in place.
Recommendation:
We recommend the Wisconsin Department of Administration develop and implement procedures to:
-obtain the service organization audit report for the computer system used to administer the Homeowner Assistance Fund;
-complete a review of the service organization audit report, assess the effectiveness of the internal controls on the computer system maintained by the service organization, and document its review; and
-complete a review of the complementary user entity controls at the Department of Administration that are required to be in place for it to rely on the service organization audit report, document its review, and implement user entity controls, if needed.
Finding 2023-101: Homeowner Assistance Fund—Service Organization Internal Controls
COVID-19—Homeowner Assistance Fund (Assistance Listing number 21.026)
Award Number Award Year
None 2021
Questioned Costs: None
Type of Finding: Material Weakness, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments
Background:
Under ARPA, Treasury provided funding to DEHCR for HAF. This program was established to mitigate financial hardships associated with the public health emergency, including for the purpose of preventing homeowner mortgage delinquencies, defaults, foreclosures, losses of utilities or home energy services, and displacements of homeowners experiencing financial hardship after January 21, 2020.
To administer HAF, DOA contracted with a service organization to host and maintain a computer system to assist in determining the eligibility of individuals applying for benefits and approving these benefits. In addition, DOA contracted with community action agencies to intake and review individual applications for eligibility. The community action agencies were responsible for entering the applications into the computer system and following DOA’s policies and procedures regarding documentation requirements.
Criteria:
To be eligible for HAF under Treasury guidance, a homeowner must have experienced a financial hardship after January 21, 2020, and have income equal to or less than 150 percent of the area median income or 100 percent of the median income for the United States, whichever is greater.
Treasury guidance indicates two permissible approaches for income verification:
-a written attestation of household income and supporting documentation, such as paystubs, W-2 or other wage statements, IRS Form 1099s, tax filings, or an attestation from an employer; or
-a written attestation of household income and a reasonable fact-specific proxy for household income, such as reliance on data regarding average incomes in the household’s geographic area.
In its Wisconsin Help for Homeowners Program (WHH) Manual, DOA indicates two permissible approaches to document income eligibility:
-a written attestation of household income and documentation such as paystubs, W-2 or other wage statements, IRS Form 1099s, tax filings, or an attestation from an employer; or
-a written attestation of household income and the applicant’s most recent IRS tax return.
Condition:
We tested a sample of 60 applicants who applied for and received benefits under HAF during FY 2022-23. We found two applicants DOA approved for benefits that, based on the documentation in the HAF program computer system, did not meet the income eligibility documentation requirements. For one applicant, there was no documentation of a completed income attestation with supporting documentation at the time DOA approved the benefit payment. For another applicant, the documentation in the computer system showed the household’s income was greater than 100 percent of the median income based on the household size reported at the time of application.
Context:
DOA expended $47.8 million in HAF funding during FY 2022-23. DOA reported that $43.9 million, or 91.8 percent, of the expenditures were benefit payments made on behalf of applicants to various entities, including mortgage and utility companies. We evaluated Treasury guidance related to HAF, discussed the application procedures with DOA staff, and reviewed DOA’s WHH Manual. We selected a random sample of 60 applicants who received HAF benefits in FY 2022-23, and we reviewed available documentation in the HAF program computer system.
Questioned Costs:
We question $10,886 in water, gas, electrical, and mortgage assistance benefits paid on behalf of two applicants for whom DOA did not have adequate supporting income documentation at the time of benefit approval in the HAF program computer system. We also question an undetermined amount for applicants that we did not test.
Effect:
DOA provided homeowner assistance to applicants who may not have been eligible to receive HAF benefits, which may have resulted in improper payments.
Cause:
Prior to approving the benefit payments during FY 2022-23, DOA did not complete a sufficient review to ensure there was adequate supporting documentation entered into the HAF program computer system by the community action agencies. Supporting documentation was either not obtained and evaluated or was obtained but not included in the HAF program computer system by the community action agencies.
After we brought these exceptions to the attention of DOA, staff reached out to the applicants. Based on the additional information provided, DOA determined the applicants were eligible for HAF.
Recommendation:
We recommend the Wisconsin Department of Administration:
-revise its procedures to ensure the Department of Administration completes a sufficient review to ensure adequate supporting documentation is included in the Homeowner Assistance Fund program’s computer system prior to an approval of the benefit payment; and
-provide training or other technical assistance to the community action agencies on the adequacy of supporting documentation agencies are to obtain, evaluate, and enter into the Homeowner Assistance Fund program’s computer system.
Finding 2023-104: Homeowner Assistance Fund—Documentation to Support Applicant Eligibility and Benefit Payments
COVID-19—Homeowner Assistance Fund (Assistance Listing number 21.026)
Award Number Award Year
None 2021
Questioned Costs: $10,886, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from Treasury. CSLFRF was created under ARPA and is administered by DOA. CSLFRF funding has certain requirements, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA expended funding under CSLFRF for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by CSLFRF.
Criteria:
Under 2 CFR s. 200.303, DOA is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DOA is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DOA must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
Condition:
In our review of expenditures under the CSLFRF program, we identified unallowable costs that were charged to the CSLFRF program. We found:
-DOA overpaid one school district by $10,279 for the Get Kids Ahead K-12 Mental Health Initiative;
-DOA overpaid one local law enforcement agency by $129,595 for the Law Enforcement Assistance Program; and
-DOA overpaid one local law enforcement agency by $1,188 for the Law Enforcement Assistance Program.
Context:
During FY 2022-23, the State expended $747.5 million in CSLFRF funding. DOA expended $419.8 milion, including $15.5 million under the Get Kids Ahead K-12 Mental Health Initiative and $6.1 million under the Law Enforcement Assistance Program. We reviewed a sample of expenditures under each of these programs, assessed the supporting documentation, and inquired of DOA staff regarding the expenditues.
Questioned Costs:
$141,062
Effect:
DOA may have charged unallowable costs to the CSLFRF program, which may have resulted in improper payments.
Cause:
The overpayment to the school district under the Get Kids Ahead K-12 Mental Health Initiative resulted from an error in the upload of the payment in STAR, the State’s accounting system.
The overpayment to the law enforcement agency resulted because staff paid the full allocation of $144,744 to the agency, rather than the request for reimbursement of $15,149. The second overpayment resulted from an error made by DOA when addressing the correction for an amount reported in the expense report of a law enforcement agency.
Recommendation:
We recommend the Wisconsin Department of Administration ensure only allowable costs are charged to federal grant programs, and work with the U.S. Department of the Treasury to resolve the questioned costs we identified related to the Coronavirus State and Local Fiscal Recovery Funds program.
Finding 2023-105: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $141,062
Type of Finding: Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22 from the U.S. Department of the Treasury (Treasury). CSLFRF was created under ARPA and is administered DOA. CSLFRF funding has certain stipulations, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA entered into a memorandum of understanding (MOU) with DHS to administer several different programs to be funded by the CSLFRF program, including the DHS COVID Operations Funding Program, and entered into two agreements related to providing funding for the purchase of COVID-19 testing supplies and the laboratory diagnostic services necessary to complete testing of samples. Under the COVID-19 LAB Testing and Specimen Collection Program, funding was used to purchase COVID-19 testing supplies and to contract with vendors to transport testing supplies, collect specimens, and to test the specimens for COVID-19. Under the COVID-19 Testing Pilot Program, DHS contracted with local and tribal public health agencies and their partner health care providers, which DHS calls community partners, to reimburse costs associated with conducting COVID-19 testing at community testing sites.
Criteria:
In accordance with 2 CFR s. 200.303, DHS is responsible for establishing and maintaining effective internal control over federal awards that provides reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DHS is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DHS must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
ARPA stipulates that eligible expenditures under CSLFRF must be incurred between March 3, 2021, and December 31, 2024, and expended by December 31, 2026.
Condition:
DHS staff indicated that under the COVID-19 LAB Testing and Specimen Collection Program, staff reconciled vendor invoices to the Wisconsin Electronic Disease Surveillance System (WEDSS) data to ensure the amounts billed from the vendor are accurate and are based on testing completed. WEDSS is the DHS application to collect information on communicable diseases and includes reporting on COVID-19 testing. For 1 of 13 invoices we reviewed for this program, DHS did not have documentation to support that a reconciliation was completed. Further, for this same invoice, a portion of the tests were provided outside of the period of performance for the CSLFRF program.
For the COVID-19 Testing Pilot Program, DHS staff reviewed invoices from its community partners for reasonableness and approved the invoices for payment. However, DHS did not have sufficient procedures specifying how staff reviewed and approved the invoices. For five of seven invoices tested for this program, DHS did not have sufficient supporting documentation in STAR to demonstrate staff had reviewed the invoices for overall reasonableness, such as by reviewing WEDSS data, when available, or by asking the community partner for more detail to support the invoice.
We requested WEDSS or other data from DHS to support the invoices. For one invoice, DHS provided documentation of the results of a reconciliation between the community partner invoice and WEDSS data. For two invoices, DHS provided documentation that indicated more tests were recorded in WEDSS than those for which the community partner had requested reimbursement on its invoice.
For one invoice, which totaled $4,560, DHS did not provide any additional documentation to support that the tests were reported in WEDSS. For one other invoice, DHS paid the tribal public health agency $94,300 based on an invoice without detailed support for the number of tests. DHS indicated that the tribal public health agency used a different reporting system, but DHS did not have documentation to support the invoice. Further, a portion of the testing was performed outside of the period of performance for the CSLFRF program.
Finally, we found DHS charged costs from DOA central billings related to software license fees for the period July 1, 2020, through June 30, 2021, to CSLFRF funding under the DHS COVID Operations Funding Program. We estimate that $2,965 of
these charges were incurred prior to March 3, 2021, and were outside the period of performance for the CSLFRF program.
Context:
During FY 2022-23, DHS expended $125.6 million in CSLFRF funding, including $16.7 million under the DHS COVID Operations Funding Program and a total of $32.9 million related to the COVID-19 Testing Pilot Program and the COVID-19
LAB Testing and Specimen Collection Program. We interviewed DHS staff to gain an understanding of DHS’s administration of the CSLFRF funding, including how it reviewed invoices related to the testing programs. We requested documentation of
the WEDSS reconciliations and other support for the payments made for the testing programs.
We also reviewed unusual line descriptions in the accounting data and found the references to FY 2020-21 payments, which resulted in the identification of the DOA central billings. We discussed the underlying expenses with DHS staff to further understand if they were incurred outside of the period of performance.
Questioned Costs:
We question $103,671, which consists of:
-$94,300 paid to a community partner under the COVID-19 Testing Pilot Program;
-$4,560 paid to a community partner under the COVID-19 Testing Pilot Program;
-$2,965 related to the software license costs that were charged to the DHS COVID Operations Funding Program outside of the period of performance; and
-$1,846 paid for testing completed outside of the period of performance for one of the testing laboratories under the
COVID-19 LAB Testing and Specimen Collection Program.
In addition, we question an undetermined amount related to the invoices for which DHS provided documentation to indicate that testing had occurred but for which it did not complete a full reconciliation.
Effect:
DHS may have charged unallowable costs to the CSLFRF program, resulting in improper payments.
Cause:
DHS staff indicated that turnover of the employees who administered these programs in 2022 made it difficult for DHS to answer our questions and to obtain any further documentation. DHS staff noted that staff approving the invoices would not have had an awareness of the period of performance requirements for the CSLFRF program. DHS staff noted that the two testing programs were administered by different units within DHS and different procedures had been followed prior to FY 2022-23. Further, staff indicated that procedures were changed for these two programs in FY 2022-23 and that the invoices we had questioned were approved during that transition period. We note that the invoices about which we made inquiries related largely to COVID-19 testing completed in FY 2021-22 that was billed to DHS but not processed and paid until early in FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-review its current procedures for approving invoices related to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program to ensure the steps required for approving invoices are appropriate and documented, and that documentation is maintained either in STAR or in a central location accessible in the event of employee turnover;
-take additional steps to ensure that expenditures charged to the CSLFRF program are within the period of performance;
-provide training to staff responsible for approving invoices to ensure staff understand what documentation is required to support approvals and the required period of performance for the CSLFRF program; and
-work with the Wisconsin Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the CSLFRF program.
Finding 2023-307: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $103,671, Plus an Undetermined Amount
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from Treasury. CSLFRF was created under ARPA and is administered by DOA. CSLFRF funding has certain requirements, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA entered into a memorandum of understanding with DHS to use CSLFRF funding to administer the Emergency Medical Services (EMS) Financial Support program, which has two components:
-additional funding to DHS’s existing EMS Funding Assistance Program; and
-a one-time flexible grant program for emergency medical response services.
Criteria:
Under 2 CFR s. 200.303, DHS is responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DHS is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DHS must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
Condition:
In our review of expenditures under the CSLFRF program, we identified costs charged to the CSLFRF program that were unallowable and costs that were outside of the period of performance. We found the following:
-For two providers, DHS reimbursed $12,210 but was unable to provide the expense reports or supporting documentation. We could not determine whether the costs were allowable or incurred within the period of performance.
-For one provider, DHS did not have documentation to support that $7,607 in costs were within the period of performance for the CSLFRF program.
Context:
During FY 2022-23, the State expended $747.5 million in CSLFRF funding. DHS expended $128.2 million, including $35.9 million under the Emergency Medical Services Financial Support program. We reviewed a sample of expenditures under this program, assessed supporting documentation, and inquired of DHS staff regarding the expenditures.
Questioned Costs:
$19,817
Effect:
DHS may have charged unallowable costs to the CSLFRF program, which may have resulted in improper payments.
Cause:
DHS either did not obtain or did not retain sufficient documentation to support the reimbursements. The process used to reimburse providers based on an expense report may have contributed to the lack of documentation.
Recommendation:
We recommend the Wisconsin Department of Health Services ensure it retains documentation to support the costs charged to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, and work with the Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs we identified.
Finding 2023-309: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $19,817
Type of Finding: Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
Background:
The State was advanced a total of $3.0 billion under the CSLFRF program in FY 2020-21 and FY 2021-22, from the U.S. Department of the Treasury (Treasury). CSLFRF was created under the American Rescue Plan Act (ARPA) and is administered by DOA. CSLFRF funding has certain requirements, including that the funds must be used to:
-respond to the public health emergency or its negative economic impacts;
-respond to the needs of workers performing essential work during the public health emergency;
-provide government services to the extent revenue losses due to the public health emergency reduced revenues; and
-make necessary investments in water, sewer, or broadband infrastructure.
DOA expended funding under the CSLFRF program for various programs that it established. In addition, DOA entered into a memorandum of understanding (MOU) with various state agencies to administer several different programs funded by the CSLFRF program. DOA entered into an MOU with DOT to fund certain DOT payroll costs for the State Patrol Overtime Pay Program.
Criteria:
Under 2 CFR s. 200.303, DOA and state agencies administering CSLFRF funding are responsible for establishing and maintaining effective internal control over federal awards to provide reasonable assurance that federal awards are managed in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Further, DOA is required to follow Treasury guidance that requires it to maintain documentation to demonstrate that CSLFRF funding was used in accordance with federal regulations. Under Treasury Final Rule (31 CFR Part 35), DOA and state agencies administering CSLFRF funding must establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements of CSLFRF funding.
Condition:
In our review of expenditures under the CSLFRF program, we identified unallowable costs that were charged to the CSLFRF program. We found that DOT charged $2,173 in salaries for employees not working in the State Patrol Division for the State Patrol Overtime Pay Program.
Context:
During FY 2022-23, the State expended $747.5 million in CSLFRF funding. DOT expended $1.4 million under the State Patrol Overtime Pay Program. We reviewed a sample of expenditures under this program, assessed the underlying support documentation, and inquired of DOT staff regarding the expenditures.
Questioned Costs:
$2,173
Effect:
DOT may have charged unallowable costs to the CSLFRF program, which may have resulted in improper payments.
Cause:
The unallowable costs related to the DOT State Patrol Overtime Pay Program resulted from a coding error in one pay period that resulted in certain job titles not associated with the State Patrol Division being included in the charge to the CSLFRF-funded program.
Recommendation:
We recommend the Wisconsin Department of Transportation ensure only allowable costs are charged to federal grant programs, and work with the Department of Administration and the U.S. Department of the Treasury to resolve the questioned costs related to the Coronavirus State and Local Fiscal Recovery Funds program.
Finding 2023-500: Coronavirus State and Local Fiscal Recovery Funds—Unallowable Costs
COVID-19—Coronavirus State and Local Fiscal Recovery Funds
(Assistance Listing number 21.027)
Award Number Award Year
None 2021
Questioned Costs: $2,173
Type of Finding: Noncompliance
Response from the Wisconsin Department of Transportation: The Wisconsin Department of Transportation agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to
the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
DNR did not have documentation that it completed risk assessments for GLRI subrecipients during FY 2022-23. Although DNR reviewed subrecipient reimbursement requests and progress reports as its primary monitoring activity, the sufficiency of this level of monitoring cannot be assured without performing the required risk assessments. We also found that DNR did not obtain the single audit report from the Federal Audit Clearinghouse (FAC) or have documentation to support that it completed a review of the report for the largest subrecipient that received GLRI program funding in FY 2022 23.
Context:
DNR expended $13.2 million under the GLRI program during FY 2022-23, including $7.2 million that it provided to 18 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and subrecipients to identify whether DNR had communicated the required award information to subrecipients. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its subrecipients are not in compliance with all federal requirements.
Cause:
DNR did not have a plan to monitor subrecipients for the GLRI program based on subrecipient risk assessments. DNR attributed the lack of documented risk assessments for GLRI program subrecipients to its close working relationship with
the subrecipients and its reliance on program managers to assess and complete monitoring as needed.
In addition, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. DNR staff indicated that they relied on the subrecipient to notify DNR when a single audit
report was submitted to the FAC rather than DNR staff independently identifying and reviewing all relevant GLRI subrecipient single audit reports submitted to the FAC. Further, the DNR staff person completing single audit report reviews for DNR grant programs was not aware of all 18 GLRI subrecipients and had not requested this information in order to independently identify from the FAC those single audit reports that should have been reviewed.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop a written monitoring plan for the Geographic Programs - Great Lakes Restoration Initiative program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities performed.
Finding 2023-800: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E01568 2015
00E02252 2017
00E02288 2017
00E02348 2018
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
01E03010 2022
00E03149 2022
00E03187 2022
00E03252 2022
00E03250 2022
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Background:
DNR receives federal funding from the U.S. Environmental Protection Agency (EPA) for the GLRI program. The objective of the GLRI program is to advance protection and restoration of the Great Lakes Basin Ecosystem. To administer the GLRI program, DNR contracts with subrecipients located around the State, including counties, cities, and sewage districts.
Criteria:
DNR administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to
the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DNR to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DNR to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DNR to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
An EPA subaward policy further clarifies that the Uniform Guidance provisions are applicable to its grant programs, including a requirement for DNR to establish and follow a system for evaluating the risks of subrecipient noncompliance with laws, regulations, and the terms and conditions of the subaward, as required by 2 CFR ss. 200.332 (b) and (d). This policy also requires DNR to document its evaluations. In addition, EPA’s policy requires that DNR establish and follow a process for deciding whether to impose additional requirements on subrecipients based on the risk assessments.
Condition:
DNR did not have documentation that it completed risk assessments for GLRI subrecipients during FY 2022-23. Although DNR reviewed subrecipient reimbursement requests and progress reports as its primary monitoring activity, the sufficiency of this level of monitoring cannot be assured without performing the required risk assessments. We also found that DNR did not obtain the single audit report from the Federal Audit Clearinghouse (FAC) or have documentation to support that it completed a review of the report for the largest subrecipient that received GLRI program funding in FY 2022 23.
Context:
DNR expended $13.2 million under the GLRI program during FY 2022-23, including $7.2 million that it provided to 18 subrecipients. We interviewed DNR staff to gain an understanding of its procedures for monitoring subrecipients. We reviewed the agreements between DNR and subrecipients to identify whether DNR had communicated the required award information to subrecipients. We also reviewed monitoring activities DNR performed for the GLRI program, including DNR’s process to review subrecipient single audit reports and DNR’s monitoring of subrecipients through progress reporting and reimbursement requests.
Questioned Costs:
None.
Effect:
Because DNR did not comply with all subrecipient monitoring compliance requirements for the GLRI program, there is a higher risk that DNR and its subrecipients are not in compliance with all federal requirements.
Cause:
DNR did not have a plan to monitor subrecipients for the GLRI program based on subrecipient risk assessments. DNR attributed the lack of documented risk assessments for GLRI program subrecipients to its close working relationship with
the subrecipients and its reliance on program managers to assess and complete monitoring as needed.
In addition, DNR did not have sufficient procedures in place to ensure all GLRI subrecipient single audit reports were being obtained and reviewed. DNR staff indicated that they relied on the subrecipient to notify DNR when a single audit
report was submitted to the FAC rather than DNR staff independently identifying and reviewing all relevant GLRI subrecipient single audit reports submitted to the FAC. Further, the DNR staff person completing single audit report reviews for DNR grant programs was not aware of all 18 GLRI subrecipients and had not requested this information in order to independently identify from the FAC those single audit reports that should have been reviewed.
Recommendation:
We recommend the Wisconsin Department of Natural Resources develop a written monitoring plan for the Geographic Programs - Great Lakes Restoration Initiative program that includes policies and procedures for:
-completing risk assessments for each subrecipient;
-the specific monitoring steps that are required based on the level of subrecipient risk identified in a risk assessment;
-independently identifying and reviewing subrecipient single audit reports, if applicable; and
-maintaining documentation of all subrecipient monitoring activities performed.
Finding 2023-800: Geographic Programs - Great Lakes Restoration Initiative—Subrecipient Monitoring
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E01568 2015
00E02252 2017
00E02288 2017
00E02348 2018
00E02349 2018
00E02393 2018
00E02456 2019
00E02490 2019
00E02824 2020
00E02979 2021
00E02975 2021
00E03010 2021
01E03010 2022
00E03149 2022
00E03187 2022
00E03252 2022
00E03250 2022
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Natural Resources: The Wisconsin Department of Natural Resources agrees with the audit finding and recommendations.
Education Stabilization Fund—ESSER Fund Reporting
Background:
The U.S. Department of Education provides funding to DPI for several subprograms of the Education Stabilization Fund grant program, which includes the Elementary and Secondary School Emergency Relief (ESSER) Fund (Assistance Listing number 84.425). The purpose of the ESSER Fund is to provide local educational agencies (LEAs), including charter schools, with emergency relief funds to address the effects of the public health emergency on elementary and secondary schools. The ESSER Fund includes three rounds of funding. ESSER I was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, ESSER II was created by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and ESSER III was created by the American Rescue Plan Act (ARPA).
DPI used the ESSER funding to address various LEA needs related to the public health emergency, including personal protective equipment, sanitation, and technology equipment. During FY 2022 23, DPI expended $469.1 million under the ESSER Fund, of which $12.4 million was expended under ESSER I, $204.8 million was expended under ESSER II, and $251.9 million was expended under ESSER III. During our FY 2020-21 audit, we issued Finding 2021-400 (report 22 5) related to a lack of documentation at DPI for the first annual ESSER report.
Criteria:
Under 2 CFR s. 200.303, DPI is required to establish and maintain effective internal controls over its federal programs to provide reasonable assurance that the federal programs are administered in compliance with federal laws and regulations as well as the terms and conditions of its federal awards. This includes effective internal controls over the preparation of reports for the federal government. Under 34 CFR s. 76.720 (b), DPI is required to submit an annual report to the U.S. Department of Education on the uses of ESSER funds. In addition, 34 CFR s. 76.730 requires that DPI retain supporting documentation for a federal award. In September 2022, DPI submitted its second ESSER annual report. This report was to include activity from March 13, 2020, through June 30, 2021.
Condition:
In its second annual ESSER report submitted during FY 2022 23, we identified that DPI reported inaccurate ESSER expenditure amounts for 6 of 26 LEAs whose underlying data we reviewed for the period January 1, 2021, through June 30, 2021. For example, for one LEA DPI reported $13.5 million in ESSER expenditures for the period January 1, 2021, through June 30, 2021, when information on expenditures within its grant management system reported $22.0 million in ESSER expenditures for that LEA during that period.
Context:
We interviewed DPI staff to gain an understanding of the procedures for preparing the ESSER Fund annual report and for submitting the report to the U.S. Department of Education. The reporting requires DPI to accumulate certain information for the 449 LEA receipients of ESSER funding. We requested copies of the information accumulated for the second ESSER annual report and used information from DPI’s grant management system to assess the accuracy of the amounts included in the reports. We selected 26 LEAs to review the reported information for the ESSER expenditures, which included the State’s largest LEA and 25 additional LEAs.
Questioned Costs:
None.
Effect:
DPI cannot be assured that it reported complete and accurate information to the
U.S. Department of Education on the State’s uses of ESSER funding.
Cause:
DPI indicated the data it compiled from the grant management system for the first annual ESSER report resulted in significant data quality issues that it had been identifying and correcting. One of the primary reasons for the data quality issues related to how ESSER funding allocated to private schools was compiled and extracted by the grant management system. We found DPI had addressed the data quality issues for reported LEA expenditures through December 31, 2020. However, ESSER expenditure data for the period from January 1, 2021, through June 30, 2021, included LEAs that had related private school allocations for which we identified errors. DPI acknowledged that errors could be present in certain LEA expenditure amounts when there was a private school allocation. However, to identify and correct such errors when compiling the second annual ESSER report, DPI had not completed a review of the grant management data for each LEA for the period from January 1, 2021, through June 30, 2021.
Recommendation:
We recommend the Wisconsin Department of Public Instruction make changes to its grant management system or develop alternative procedures to ensure that all expenditure information is accurately reported for the Elementary and Secondary
School Emergency Relief Fund program.
Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting
COVID-19—Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425D)
Award Numbers Award Years
S425D200044 2020
S425D210044 2021
Questioned Costs: None
COVID-19—American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425U)
Award Numbers Award Years
S425U210044 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendation.
Education Stabilization Fund—ESSER Fund Reporting
Background:
The U.S. Department of Education provides funding to DPI for several subprograms of the Education Stabilization Fund grant program, which includes the Elementary and Secondary School Emergency Relief (ESSER) Fund (Assistance Listing number 84.425). The purpose of the ESSER Fund is to provide local educational agencies (LEAs), including charter schools, with emergency relief funds to address the effects of the public health emergency on elementary and secondary schools. The ESSER Fund includes three rounds of funding. ESSER I was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, ESSER II was created by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and ESSER III was created by the American Rescue Plan Act (ARPA).
DPI used the ESSER funding to address various LEA needs related to the public health emergency, including personal protective equipment, sanitation, and technology equipment. During FY 2022 23, DPI expended $469.1 million under the ESSER Fund, of which $12.4 million was expended under ESSER I, $204.8 million was expended under ESSER II, and $251.9 million was expended under ESSER III. During our FY 2020-21 audit, we issued Finding 2021-400 (report 22 5) related to a lack of documentation at DPI for the first annual ESSER report.
Criteria:
Under 2 CFR s. 200.303, DPI is required to establish and maintain effective internal controls over its federal programs to provide reasonable assurance that the federal programs are administered in compliance with federal laws and regulations as well as the terms and conditions of its federal awards. This includes effective internal controls over the preparation of reports for the federal government. Under 34 CFR s. 76.720 (b), DPI is required to submit an annual report to the U.S. Department of Education on the uses of ESSER funds. In addition, 34 CFR s. 76.730 requires that DPI retain supporting documentation for a federal award. In September 2022, DPI submitted its second ESSER annual report. This report was to include activity from March 13, 2020, through June 30, 2021.
Condition:
In its second annual ESSER report submitted during FY 2022 23, we identified that DPI reported inaccurate ESSER expenditure amounts for 6 of 26 LEAs whose underlying data we reviewed for the period January 1, 2021, through June 30, 2021. For example, for one LEA DPI reported $13.5 million in ESSER expenditures for the period January 1, 2021, through June 30, 2021, when information on expenditures within its grant management system reported $22.0 million in ESSER expenditures for that LEA during that period.
Context:
We interviewed DPI staff to gain an understanding of the procedures for preparing the ESSER Fund annual report and for submitting the report to the U.S. Department of Education. The reporting requires DPI to accumulate certain information for the 449 LEA receipients of ESSER funding. We requested copies of the information accumulated for the second ESSER annual report and used information from DPI’s grant management system to assess the accuracy of the amounts included in the reports. We selected 26 LEAs to review the reported information for the ESSER expenditures, which included the State’s largest LEA and 25 additional LEAs.
Questioned Costs:
None.
Effect:
DPI cannot be assured that it reported complete and accurate information to the
U.S. Department of Education on the State’s uses of ESSER funding.
Cause:
DPI indicated the data it compiled from the grant management system for the first annual ESSER report resulted in significant data quality issues that it had been identifying and correcting. One of the primary reasons for the data quality issues related to how ESSER funding allocated to private schools was compiled and extracted by the grant management system. We found DPI had addressed the data quality issues for reported LEA expenditures through December 31, 2020. However, ESSER expenditure data for the period from January 1, 2021, through June 30, 2021, included LEAs that had related private school allocations for which we identified errors. DPI acknowledged that errors could be present in certain LEA expenditure amounts when there was a private school allocation. However, to identify and correct such errors when compiling the second annual ESSER report, DPI had not completed a review of the grant management data for each LEA for the period from January 1, 2021, through June 30, 2021.
Recommendation:
We recommend the Wisconsin Department of Public Instruction make changes to its grant management system or develop alternative procedures to ensure that all expenditure information is accurately reported for the Elementary and Secondary
School Emergency Relief Fund program.
Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting
COVID-19—Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425D)
Award Numbers Award Years
S425D200044 2020
S425D210044 2021
Questioned Costs: None
COVID-19—American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425U)
Award Numbers Award Years
S425U210044 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendation.
Education Stabilization Fund—ESSER Fund Reporting
Background:
The U.S. Department of Education provides funding to DPI for several subprograms of the Education Stabilization Fund grant program, which includes the Elementary and Secondary School Emergency Relief (ESSER) Fund (Assistance Listing number 84.425). The purpose of the ESSER Fund is to provide local educational agencies (LEAs), including charter schools, with emergency relief funds to address the effects of the public health emergency on elementary and secondary schools. The ESSER Fund includes three rounds of funding. ESSER I was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, ESSER II was created by the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, and ESSER III was created by the American Rescue Plan Act (ARPA).
DPI used the ESSER funding to address various LEA needs related to the public health emergency, including personal protective equipment, sanitation, and technology equipment. During FY 2022 23, DPI expended $469.1 million under the ESSER Fund, of which $12.4 million was expended under ESSER I, $204.8 million was expended under ESSER II, and $251.9 million was expended under ESSER III. During our FY 2020-21 audit, we issued Finding 2021-400 (report 22 5) related to a lack of documentation at DPI for the first annual ESSER report.
Criteria:
Under 2 CFR s. 200.303, DPI is required to establish and maintain effective internal controls over its federal programs to provide reasonable assurance that the federal programs are administered in compliance with federal laws and regulations as well as the terms and conditions of its federal awards. This includes effective internal controls over the preparation of reports for the federal government. Under 34 CFR s. 76.720 (b), DPI is required to submit an annual report to the U.S. Department of Education on the uses of ESSER funds. In addition, 34 CFR s. 76.730 requires that DPI retain supporting documentation for a federal award. In September 2022, DPI submitted its second ESSER annual report. This report was to include activity from March 13, 2020, through June 30, 2021.
Condition:
In its second annual ESSER report submitted during FY 2022 23, we identified that DPI reported inaccurate ESSER expenditure amounts for 6 of 26 LEAs whose underlying data we reviewed for the period January 1, 2021, through June 30, 2021. For example, for one LEA DPI reported $13.5 million in ESSER expenditures for the period January 1, 2021, through June 30, 2021, when information on expenditures within its grant management system reported $22.0 million in ESSER expenditures for that LEA during that period.
Context:
We interviewed DPI staff to gain an understanding of the procedures for preparing the ESSER Fund annual report and for submitting the report to the U.S. Department of Education. The reporting requires DPI to accumulate certain information for the 449 LEA receipients of ESSER funding. We requested copies of the information accumulated for the second ESSER annual report and used information from DPI’s grant management system to assess the accuracy of the amounts included in the reports. We selected 26 LEAs to review the reported information for the ESSER expenditures, which included the State’s largest LEA and 25 additional LEAs.
Questioned Costs:
None.
Effect:
DPI cannot be assured that it reported complete and accurate information to the
U.S. Department of Education on the State’s uses of ESSER funding.
Cause:
DPI indicated the data it compiled from the grant management system for the first annual ESSER report resulted in significant data quality issues that it had been identifying and correcting. One of the primary reasons for the data quality issues related to how ESSER funding allocated to private schools was compiled and extracted by the grant management system. We found DPI had addressed the data quality issues for reported LEA expenditures through December 31, 2020. However, ESSER expenditure data for the period from January 1, 2021, through June 30, 2021, included LEAs that had related private school allocations for which we identified errors. DPI acknowledged that errors could be present in certain LEA expenditure amounts when there was a private school allocation. However, to identify and correct such errors when compiling the second annual ESSER report, DPI had not completed a review of the grant management data for each LEA for the period from January 1, 2021, through June 30, 2021.
Recommendation:
We recommend the Wisconsin Department of Public Instruction make changes to its grant management system or develop alternative procedures to ensure that all expenditure information is accurately reported for the Elementary and Secondary
School Emergency Relief Fund program.
Finding 2023-400: Education Stabilization Fund—ESSER Fund Reporting
COVID-19—Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425D)
Award Numbers Award Years
S425D200044 2020
S425D210044 2021
Questioned Costs: None
COVID-19—American Rescue Plan - Elementary and Secondary School Emergency Relief Fund (Assistance Listing number 84.425U)
Award Numbers Award Years
S425U210044 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Public Instruction: The Wisconsin Department of Public Instruction agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Aging Cluster—Subrecipient Monitoring
Background:
The DHHS Administration for Community Living provides funding to DHS for the Aging Cluster. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. To administer the Aging Cluster, DHS contracts with three Area Agencies on Aging and used CARS to process reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessment. DHS policies indicate that monitoring must include reviewing financial and performance reports required by DHS. Additionally, per DHS policies, monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site review of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or an on-site visit.
Condition:
DHS performed the required risk assessments for each Area Agency on Aging and, as a part of its plan for monitoring each entity, DHS:
-required the submission of both a quarterly financial report and a separate semiannual financial report for use in monitoring activities and to provide information for DHS to prepare semiannual financial reports to submit to the federal government; and
-established regular monthly and quarterly program and fiscal oversight meetings to provide a forum for the discussion of issues, to answer questions, and to provide technical guidance.
During FY 2022-23, DHS received 10 of the 12 quarterly financial reports from the Area Agencies on Aging. Although DHS indicated it reviewed each quarterly and semiannual financial report submitted by the Area Agencies on Aging, DHS did not document how these reports were reviewed, when they were reviewed, or the extent of the review process. For example, DHS did not have documentation indicating who performed the review. Related to the monthly and quarterly meetings held with the Area Agencies on Aging during FY 2022-23, DHS did not document attendance, agendas, or minutes for these oversight meetings.
Context:
DHS expended $32.5 million under the Aging Cluster during FY 2022-23, including $31.3 million that was provided to the Area Agencies on Aging. We interviewed DHS staff to gain an understanding of its policies and procedures for monitoring subrecipients for the Aging Cluster, and we reviewed DHS manuals and guidance related to subrecipient monitoring.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures were not documented, DHS cannot demonstrate that it performed adequate monitoring of each Area Agency on Aging. Therefore, DHS is at increased risk of noncompliance with federal regulations for the Aging Cluster. Further, due to the lack of complete quarterly reporting from one Area Agency on Aging, DHS submitted incomplete information in three mid-year financial reports to the federal government. Among these three reports, we estimate that DHS did not report approximately $1.6 million in program income.
Cause:
Because the program has only three significant subrecipients, the procedures implemented by DHS were more informal and relied on the knowledge of the staff persons performing the monitoring, as well as frequent interactions between DHS
staff and each Area Agency on Aging. Formal procedures were not developed and implemented for the tracking, review, and documentation of the receipt and review of the quarterly and the semiannual financial reports. Formal procedures were not developed and implemented for maintaining documentation of oversight meetings that were held. In prior years, DHS had performed an on-site visit as a part of its monitoring plan. As a result of the public health emergency, these on-site visits were not performed during FY 2022-23.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-create a centralized tracking process to monitor the receipt of the quarterly financial reports and semiannual financial reports from each Area Agency on Aging, including follow-up procedures when reports are not provided;
-implement procedures to document the review and approval of the quarterly financial reports and semiannual financial reports, including related follow-up and resolution; and
-develop and maintain in a central location documentation related to the monitoring procedures performed, including email correspondence or documentation of oversight meetings such as agendas and significant discussion topics.
Finding 2023-308: Aging Cluster—Subrecipient Monitoring
COVID-19—Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2001WISSC3 2020
2001WISSC6 2020
2101WIVAC5 2021
2101WISTPH 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part B, Grants for Supportive Services and Senior Centers (Assistance Listing number 93.044)
Award Numbers Award Years
2101WIOASS 2021
2201WIOASS 2022
2301WIOASS 2023
Questioned Costs: None
COVID-19—Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2001WIHDC2 2020
2002WIHDC3 2020
2101WICMC6 2021
2101WIHDC5 2021
2101WIHDC6 2021
Questioned Costs: None
Special Programs for the Aging, Title III, Part C, Nutrition Services (Assistance Listing number 93.045)
Award Numbers Award Years
2101WIOACM 2021
2101WIOAHD 2021
2201WIOACM 2022
2201WIOAHD 2022
2301WIOACM 2023
2301WIOAHD 2023
Questioned Costs: None
Nutrition Services Incentive Program (Assistance Listing number 93.053)
Award Numbers Award Years
2201WIOANS 2022
2301WIOANS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
Background:
CDC provides funding to DHS under the Cooperative Agreements program. The Cooperative Agreements program is intended to provide funding to rapidly respond to public health emergencies as identified by the CDC. DHS received three awards from the CDC to be funded by the Cooperative Agreements grant: COVID Crisis Response, COVID Public Health Workforce, and Monkey Pox Crisis Response.
Under the COVID Public Health Workforce award, DHS contracted with subrecipients, including local and tribal public health agencies and cooperative educational service agencies (CESAs), to administer the award. DHS uses CARS to process
the reimbursement requests for the local and tribal public health agencies. Reimbursement requests for CESAs are processed directly through STAR, the State’s accounting system, based upon review and approval of detailed invoices.
Criteria:
DHS administers federal programs that are subject to Uniform Guidance. Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance, performing desk reviews of the subrecipient’s records, and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. DHS policies note that additional verification can be performed by reviewing subrecipients financial records through a desk review or an on-site visit.
Condition:
For 1 of 11 subrecipients we reviewed, DHS was unable to provide a completed subrecipient risk assessment. In addition, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there were no procedures to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when DHS would be required to review subrecipient invoices through a desk review or an on-site visit. DHS staff indicated that all subrecipients were monitored in the same manner regardless of the risk assessment level determined.
DHS monitoring of subrecipient activity for the Cooperative Agreements program was not documented sufficiently to provide assurance that the subrecipients used the subaward for authorized purposes and in compliance with the subaward terms and conditions. DHS grant program staff collected and reviewed semiannual progress and fiscal reports for the 96 local and tribal public health agencies that received funding under the COVID Public Health Workforce award, but did not require such reporting for the CESAs. We reviewed the spreadsheet maintained by the grant program staff to track and document review of the semiannual progress and fiscal reports submitted in December 2022. We found the documentation was incomplete. We identified that for 12 of the 96 subrecipients being tracked, the spreadsheet indicated that the review was still in progress at the time of our fieldwork in February 2024. We also identified that for four subrecipients, DHS indicated in the spreadsheet that costs were denied or potentially denied. However, DHS did not note a conclusion in the spreadsheet. We requested any documentation DHS had available related to resolution of the denied or potentially denied costs. DHS provided only limited documentation, including email correspondence with certain of the subrecipients. DHS was unable to provide documentation to support that it had resolved three of the four subrecipients potentially unallowable costs.
Finally, DHS did not review subrecipient invoices through a desk review or an on-site visit of the subrecipient to assess the allowability of the costs charged to the grant.
Context:
DHS expended $15.4 million under the Cooperative Agreements grant during FY 2022-23, including $6.8 million that was provided to subrecipients. Of the $6.8 million provided to subrecipients, $5.5 million was processed through CARS.
We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of CARS, and its policies and procedures for monitoring subrecipients to ensure costs are allowable to be charged to the grant program.
For the COVID Public Health Workforce grant, DHS contracted with 96 local and tribal public health agencies and 12 CESAs to administer the program.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Cooperative Agreements program. Further, there is an increased risk of improper payments for the Cooperative Agreements program.
Cause:
DHS program staff were unable to explain why a risk assessment was not performed for the one subrecipient that did not have a risk assessment. DHS management did not establish written procedures to guide program staff in assessing the extent of subrecipient monitoring necessary for each level of subrecipient risk. As a result, program staff did not adjust monitoring procedures for subrecipients based on the risk assessment.
DHS program staff indicated that staff turnover contributed to some of the issues with the subrecipient monitoring spreadsheet and the lack of documentation of decisions that were made. Further, DHS program staff relied on the CARS payment process to determine that costs were allowable to be charged to the grant program. However, CARS payments are processed based on high-level summaries from subrecipients and would not provide sufficient detail to assess whether the costs were allowable or not.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-review the tracking spreadsheets completed in fiscal year 2022-23, and complete the assessment of the progress and fiscal reports and consideration of potential unallowable costs, document the conclusions, and return funding to the federal government if costs were determined to be unallowable;
-develop a written monitoring plan for the Cooperative Agreements program that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting review of the progress and fiscal reports; procedures for completing and documenting desk reviews or on-site visits; procedures for assessing and documenting the reliance that can be placed on review of a subrecipient’s single audit report; and procedures for documenting management oversight of the monitoring plan;
-develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence; and
-provide sufficient training to Department of Health Services staff administering the Cooperative Agreements program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined.
Finding 2023-306: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response—Subrecipient Monitoring
COVID-19—Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (Assistance Listing number 93.354)
Award Numbers Award Years
6 NU90TP922078-01 2020
1 NU90TP922132-01 2021
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Background:
DHHS provides funding to DHS for the Aging Cluster and the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program, which DHS refers to as the Health Disparities program. The Aging Cluster provides funds to assist states and area agencies in providing programs and services to support independence and wellness for older adults. The Health Disparities program provides funds to address health disparities among high-risk and underserved populations to address COVID-19-related health disparities and to advance health equity. Under this program, DHS transfers funds to UW-Madison.
DHS subawards funds under both programs to various entities, including local area aging agencies, counties, and tribes as a part of administering the program. For the Health Disparities program, UW-Madison subawards funds to other entities.
Subawards of $30,000 or more are subject to FFATA reporting. During FY 2022-23, DHS accountants were responsible for obtaining and reviewing federal grant subaward information and uploading it into FSRS.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the Aging Cluster and the Health Disparities program, DHS has overall responsibility for FFATA reporting. DHS is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward that exceed this amount. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023. Information required to be reported in FSRS includes several key data elements such as information about the recipient, the amount of the award, and the date the subaward agreement was signed.
Condition:
We selected 9 subawards for the Aging Cluster and 12 subawards for the Health Disparities program made by DHS during FY 2022-23 for testing. We found:
-for one subaward, which was awarded in November 2022 for the Health Disparities program, DHS had not reported the subaward in FSRS as of February 2024; and
-for nine subawards for the Aging Cluster and eight subawards for the Health Disparities program, DHS incorrectly reported the date the subaward agreement was signed. Instead, DHS reported either the date the subaward period began or the end of the month in which the subawards were reported in FSRS.
We also found DHS had not reported in FSRS any of the subawards to the University of Wisconsin-Madison under the Health Disparities program.
Context:
Of the $32.5 million DHS expended during FY 2022-23 under the Aging Cluster, $31.3 million was provided to subrecipients. Of the $9.6 million DHS expended in FY 2022-23 under the Health Disparities program, $3.8 million was provided to subrecipients. In addition, DHS provided $2.8 million to UW-Madison. UW-Madison provided $1.8 million of its award to subrecipients.
We interviewed DHS staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for submitting the information in FSRS. To assess if the subaward was reported in an accurate and timely manner, we requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed. We interviewed UW-Madison staff in order to understand UW-Madison’s subrecipient awards for the Health Disparities program and in order to assess the extent to which DHS communicated with UW-Madison regarding FFATA reporting.
Questioned Costs:
None.
Effect:
DHS did not comply with FFATA requirements for the accuracy and timely reporting of subawards in FSRS. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Aging Cluster or the Health Disparities program.
Cause:
For the subaward that was not reported, DHS staff indicated it was missed because the query used to obtain information for this reporting month did not accurately provide all information. Further, the information DHS used did not include the date the contract was signed and instead DHS reported based on the date the contract period began.
DHS did not have procedures in place to obtain information related to the subawards provided by UW-Madison or to determine whether responsibility for FFATA reporting could be delegated to UW-Madison.
Recommendation:
We recommend the Wisconsin Department of Health Services improve its Federal Funding Accountability and Transparency Act reporting procedures to accurately report required award information in a timely manner, including the date the subaward agreement was signed, and develop procedures to identify and report subawards made by state agencies to which it has transferred federal funding.
Finding 2023-304: Multiple Programs—Federal Funding Accountability and Transparency Act Reporting
Aging Cluster (Assistance Listing numbers 93.044/93.045/93.053)
Award Numbers Award Years
2301WIOACM 2023
2301WIOAHD 2023
2301WIOANS 2023
2301WIOASS 2023
Questioned Costs: None
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
NH75OT000030 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
Background:
The DHHS Centers for Disease Control (CDC) provides funding to DHS under the Health Disparities program. The program is intended to address health disparities for high-risk and underserved populations to address COVID-19 related health disparities and advance health equity.
To administer the award under the Health Disparities program, DHS contracted with a variety of subrecipients, including local and tribal public health agencies and nonprofit entities. DHS uses CARS to process the reimbursement requests for the subrecipients.
Criteria:
DHS administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes the following requirements related to the monitoring of subrecipients:
-2 CFR s. 200.332 (b) requires DHS to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring; and
-2 CFR s. 200.332 (d) through (f) requires DHS to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
DHS established policies requiring grant administrators to conduct a risk assessment for every subaward of federal funds and to use the risk assessment to determine the frequency and extent of monitoring. DHS policies include a subrecipient risk assessment template to assist grant administrators in completing the risk assessment and determining the risk level of the subrecipient.
DHS policies also require grant administrators to monitor subrecipients based on the risk assessments. DHS policies indicate that monitoring may include providing subrecipient training and technical assistance; performing desk reviews of the subrecipient’s records; and performing on-site reviews of the subrecipient’s records and operations. Finally, DHS policies in the Division of Public Health Bureau of Operations Contract Management Manual suggest that when CARS is used to process reimbursement requests, grant administrators should use enhanced expenditure reporting from subrecipients to ensure expenditures are allowable. These policies note that additional verification can be performed by reviewing subrecipient financial records through a desk review or on-site visit.
Condition:
DHS did not establish sufficient procedures to ensure the requirements related to subrecipient risk assessments were met. Although we found that risk assessments were completed for subrecipients, DHS did not define the level of monitoring to be performed based on the completed risk assessments. For example, there were no procedures to indicate the level of monitoring required for low-, moderate-, and high-risk subrecipients, such as when it would be required to review subrecipient invoices through a desk review or an on-site visit. Staff indicated that the level of monitoring of subrecipients is determined by the program staff working with the subrecipient.
To ensure only allowable costs were funded by the program, the Health Disparities program staff indicated that they relied on the establishment of a contract with the subrecipient, which indicated the costs that were allowable for the program. Further, staff indicated that there were ongoing interactions with the subrecipients to ensure the funding was expended appropriately. DHS provided various examples of how individual program staff interacted with subrecipients through email, periodic meetings, and the receipt of progress reports. However, as monitoring to be completed was determined by an individual program staff member, there was no procedure to ensure adequate monitoring was completed or that monitoring was consistent. Further, the documentation DHS provided did not demonstrate management oversight to ensure adequate monitoring was completed.
DHS also did not review subrecipient invoices through a desk review or an on-site visit to assess the allowability of the costs charged to the grant.
Context:
DHS expended $9.6 million under the Health Disparities program during FY 2022-23, including $3.8 million that was provided to subrecipients and was processed through CARS. DHS contracted with 87 subrecipients to administer the program. We interviewed DHS staff to gain an understanding of DHS policies and procedures for processing reimbursement requests from subrecipients, including its use of CARS, and its policies and procedures for monitoring subrecipients to ensure costs are allowable to be charged to the grant program.
Questioned Costs:
None.
Effect:
Because its subrecipient monitoring procedures are insufficient, DHS is at increased risk of noncompliance with federal regulations for the Health Disparities program. Further, there is an increased risk of improper payments for the Health Disparities program.
Cause:
DHS did not establish written procedures to guide program staff in assessing the extent of subrecipient monitoring necessary for each level of subrecipient risk. As a result, program staff did not adjust monitoring procedures for subrecipients based on the risk assessment.
DHS program staff relied on the CARS payment process and interactions with subrecipients to determine that costs were allowable to be charged to the Health Disparities program. Further, management oversight to ensure subrecipient monitoring was completed either did not occur or was not documented.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-develop a written monitoring plan for the Health Disparities program that includes a description of the subrecipient monitoring expected for low-, moderate-, and high-risk subrecipients; procedures for completing and documenting desk reviews of subrecipient invoices; procedures for assessing and documenting the reliance that can be placed on review of subrecipient single audit reports; and procedures for documenting management oversight of the monitoring plan;
-develop a central location to maintain documentation related to the subrecipient monitoring, including email correspondence; and
-provide sufficient training to the Department of Health Services staff administering the Health Disparities program to ensure all subrecipient monitoring responsibilities are completed consistently and are based on the risk assessment level determined.
Finding 2023-305: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises—Subrecipient Monitoring
COVID-19—Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises (Assistance Listing number 93.391)
Award Number Award Year
1 NH75OT000039-01 2021
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the subrecipient monitoring compliance requirement.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Background:
The U.S. Department of Housing and Urban Development (HUD) provides funding to DOA’s Division of Energy, Housing and Community Resources (DEHCR) for the CDBG program. The U.S. Department of Health and Human Services provides funding to DOA for LIHWAP. The CDBG program is intended to provide housing and expanded economic opportunities mainly for low- to moderate-income persons. LIHWAP provides financial assistance to low-income households for drinking water and wastewater service expenses.
CDBG and LIHWAP subawards of $30,000 or more are subject to Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, program staff in DEHCR were responsible for tracking grant awards and providing that information to the Bureau of Financial Management, which reviewed and summarized the award information and reported the information to DOA’s Division of Executive Budget and Finance (DEBF). DEBF was responsible for uploading the information into the FFATA Subaward Reporting System (FSRS). Beginning in March 2023, and in response to an audit finding related to FFATA reporting from our FY 2021-22 audit (report 23-4), DOA made changes in its FFATA reporting procedures.
Criteria:
Under 2 CFR s. 170, DOA is required to report subawards of $30,000 or more in FSRS, including any amendments or modifications to a subaward. This reporting must occur no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we selected 9 of the 27 CDBG subawards DOA indicated were signed in FY 2022-23. Only one of the nine subawards selected for testing was reported in FSRS in a timely manner. One subaward that was made in June 2023 had not been reported in FSRS as of the time of our fieldwork in January 2024.
In addition, we reviewed the monthly spreadsheets DEHCR used to track subawards required to be reported in FSRS. To assess the accuracy and timeliness of reporting in FSRS, we selected 7 of the 72 subaward changes that were on the monthly spreadsheets in FY 2022-23. Although the original subawards were dated from July 2018 through June 2021, we found that DOA had entered into FSRS the original subaward for each of the seven sampled items in the period from February through May 2023. Further, four of the seven subaward amendments that required an update in FSRS had not been updated as of our fieldwork in January 2024.
Finally, for LIHWAP, DOA provided funding to one subrecipient. DOA entered into a subaward agreement for $500,000 with the subrecipient in November 2021. DOA amended the agreement in September 2022 to provide an additional $500,000, and again in March 2023 to provide an additional $250,000. However, DOA did not report the subaward or the amendments in FSRS until March 2023.
Context:
Of the $82.0 million DOA expended under the CDBG program during FY 2022-23, $80.9 million was provided to subrecipients. Of the $16.5 million DOA expended under LIHWAP during FY 2022-23, $0.6 million was provided to subrecipients. We interviewed DOA staff to gain an understanding of the procedures for compiling and reviewing information for subawards and for reporting the information in FSRS. We requested subaward agreements and amendments, tracking spreadsheets, and reporting information from FSRS for each subaward to assess if the subaward was reported in an accurate and timely manner.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the CDBG program and LIHWAP. DOA did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the CDBG program and LIHWAP.
Cause:
DOA staff indicated that one employee was responsible for the management of contracts for federal programs within DEHCR during the public health emergency. Due to the volume of federal funding being managed, DOA indicated it did not prioritize FFATA reporting.
In addition, one of the subawards that was not reported for the CDBG program was a subaward funded by program income. DOA did not believe that subawards funded with program income were required to be reported in FSRS. However, officials with HUD communicated to us in writing that subawards either partially or fully funded by program income are required to be reported in FSRS.
Finally, we note that we reported a finding related to FFATA reporting for the Low-Income Home Energy Assistance Program during our FY 2021-22 audit (report 23-4). DOA indicated that at the time we reported these concerns in February 2023, it had taken steps to review subaward agreements and amendments going back several years and to update FSRS.
Recommendation:
We recommend the Wisconsin Department of Administration:
- review its procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are updated in FSRS in a timely manner; and
- develop and implement procedures to ensure subawards funded by program income for the Community Development Block Grant program are reported in the FFATA Subaward Reporting System accurately and in a timely manner or document why the subaward was exempt from FFATA reporting.
Finding 2023-100: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-DC-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Refugee and Entrant Assistance State/Replacement Designee Administered Programs—Subrecipient Monitoring
Background:
DCF receives federal funding from DHHS for the Refugee Programs. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community.
To administer the Refugee Programs, DCF contracts with subrecipients, or partner agencies, located around the State. The partner agencies are responsible for completing eligibility determinations, determining and providing benefits, and referring refugees to other community resources that may assist them.
Criteria:
DCF administers federal programs that are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Uniform Guidance includes three requirements related to the monitoring of subrecipients. First, 2 CFR s. 200.332 (a) (1) requires DCF to communicate certain award information to subrecipients at the time of the subaward. Second, 2 CFR s. 200.332 (b) requires DCF to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate nature and level of subrecipient monitoring. Finally, 2 CFR s. 200.332 (d) through (f) requires DCF to monitor the activities of the subrecipient as necessary to ensure that the subrecipient uses the subaward for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals.
Condition:
We found that DCF did not have documentation to support that it completed sufficient monitoring activities for 8 of the 25 subrecipients for the Refugee Programs during FY 2022-23. We also found that a risk assessment was not documented by DCF for one of the three subrecipients we reviewed for the Refugee Programs.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, it disbursed nearly $6.9 million to 25 subrecipients, including school districts, community centers, and social services agencies. DCF is responsible for performing subrecipient monitoring procedures for the recipients of these funds. We reviewed the agreements between DCF and subrecipients to identify whether DCF had communicated the required award information to subrecipients. We also reviewed monitoring activities performed by DCF for the Refugee Programs during FY 2022-23, including by gaining an understanding of the process DCF used for reviewing subrecipient single audit reports, the results of risk assessments completed for subrecipients, and the procedures used by DCF to monitor subrecipients through the on-site monitoring and programmatic desk reviews.
Questioned Costs:
None.
Effect:
Because DCF did not comply with all subrecipient monitoring compliance requirements for the Refugee Programs, there is a higher risk that DCF, as well as the subrecipients, are not in compliance with all federal requirements.
Cause:
DCF did not have a formal plan to monitor subrecipients for the Refugee Programs based on the risk assessment process. DCF staff in the Bureau of Refugee Programs indicated that they relied on risk assessments completed by DCF’s central audit function. However, DCF staff did not identify that risk assessments for some Refugee Programs subrecipients were not completed centrally because DCF’s central audit function does not complete risk assessments for subrecipients with expenditures below a certain threshold. DCF staff in the Bureau of Refugee Programs indicated they had performed a semiannual programmatic desk review for six of the eight subrecipients but were unable to provide documentation to evidence that such reviews were performed. DCF staff in the Bureau of Refugee Programs stated that the large increase in federal funds in the Refugee Programs and the introduction of several subprograms resulted in an increased workload for DCF staff who had to respond to other priorities of the program. According to DCF staff in the Bureau of Refugee Programs, this resulted in a reduction in the extent to which on-site monitoring could be performed.
Recommendation:
We recommend the Wisconsin Department of Children and Families:
-develop a subrecipient monitoring plan based on the risk assessment process to identify the specific monitoring steps necessary;
-establish and implement procedures to ensure risk assessments are completed for each subrecipient of the Refugee and Entrant Assistance State/Replacement Designee Administered Programs; and
-maintain documentation of all subreceipient monitoring activities performed.
Finding 2023-201: Refugee and Entrant Assistance State/Replacement Designee Administered Programs—Subrecipient Monitoring
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2201WIRCMA 2022
2301WIRCMA 2023
2101WIRSSS 2021
2201WIRSSS 2022
2301WIRSSS 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendations.
Multiple Grants—Federal Funds Accountability and Transparency Act Reporting
Background:
DCF receives federal funding from DHHS for the Refugee Programs and the CCDF Cluster. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community. The CCDF Cluster provides funds to increase availability, affordability, and quality of child care services through subsidizing child care for low-income families, as well as for activities to promote overall child care quality for all children, regardless of subsidy receipt. DCF makes subawards as part of administering both of these grant programs.
Subawards of $30,000 or more are subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DCF identified subawards subject to FFATA reporting requirements using information from DCF’s subaward tracking system. DCF staff provided that information to the Department of Administration’s (DOA’s), Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting
System (FSRS).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we reviewed six subawards we expected to have FFATA submissions during FY 2022-23 for the Refugee Programs and the CCDF Cluster. None of these six subawards were reported in a timely manner in FSRS.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, $6.7 million was provided to subrecipients. Of the $489.9 million DCF expended during FY 2022-23 under the CCDF Cluster, $54.1 million was provided to subrecipients. To determine whether subawards were reported in FSRS in an accurate and timely manner, we reviewed subawards reported in FSRS for two months of FY 2022-23. We interviewed DCF staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Refugee Programs or CCDF Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Refugee Programs or the CCDF Cluster.
Cause:
The query DCF used to identify subawards for FFATA reporting did not identify subawards based on the date the subaward was signed. Instead, the query identified subawards for reporting based on the beginning of the period of performance for the subaward. In addition, DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed, which then excluded those subawards from being identified in the query.
Recommendation:
We recommend the Department of Children and Families review the query used to determine subawards and its overall procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are input and updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-202: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funds Accountability and Transparency Act Reporting
Background:
DCF receives federal funding from DHHS for the Refugee Programs and the CCDF Cluster. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community. The CCDF Cluster provides funds to increase availability, affordability, and quality of child care services through subsidizing child care for low-income families, as well as for activities to promote overall child care quality for all children, regardless of subsidy receipt. DCF makes subawards as part of administering both of these grant programs.
Subawards of $30,000 or more are subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DCF identified subawards subject to FFATA reporting requirements using information from DCF’s subaward tracking system. DCF staff provided that information to the Department of Administration’s (DOA’s), Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting
System (FSRS).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we reviewed six subawards we expected to have FFATA submissions during FY 2022-23 for the Refugee Programs and the CCDF Cluster. None of these six subawards were reported in a timely manner in FSRS.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, $6.7 million was provided to subrecipients. Of the $489.9 million DCF expended during FY 2022-23 under the CCDF Cluster, $54.1 million was provided to subrecipients. To determine whether subawards were reported in FSRS in an accurate and timely manner, we reviewed subawards reported in FSRS for two months of FY 2022-23. We interviewed DCF staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Refugee Programs or CCDF Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Refugee Programs or the CCDF Cluster.
Cause:
The query DCF used to identify subawards for FFATA reporting did not identify subawards based on the date the subaward was signed. Instead, the query identified subawards for reporting based on the beginning of the period of performance for the subaward. In addition, DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed, which then excluded those subawards from being identified in the query.
Recommendation:
We recommend the Department of Children and Families review the query used to determine subawards and its overall procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are input and updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-202: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Federal Funds Accountability and Transparency Act Reporting
Background:
DCF receives federal funding from DHHS for the Refugee Programs and the CCDF Cluster. The Refugee Programs provide assistance to refugees to attain economic self-sufficiency soon after initial placement in a U.S. community. The CCDF Cluster provides funds to increase availability, affordability, and quality of child care services through subsidizing child care for low-income families, as well as for activities to promote overall child care quality for all children, regardless of subsidy receipt. DCF makes subawards as part of administering both of these grant programs.
Subawards of $30,000 or more are subject to the Federal Funding Accountability and Transparency Act (FFATA) reporting. During FY 2022-23, DCF identified subawards subject to FFATA reporting requirements using information from DCF’s subaward tracking system. DCF staff provided that information to the Department of Administration’s (DOA’s), Division of Executive Budget and Finance, which was responsible for uploading the information into the FFATA Subaward Reporting
System (FSRS).
Criteria:
Under 2 CFR s. 170, DCF is required to report in FSRS subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the subaward was made. For example, if the subaward was made on December 15, 2022, it must be reported in FSRS no later than January 31, 2023.
Condition:
To assess the accuracy and timeliness of FFATA reporting, we reviewed six subawards we expected to have FFATA submissions during FY 2022-23 for the Refugee Programs and the CCDF Cluster. None of these six subawards were reported in a timely manner in FSRS.
Context:
Of the $8.7 million DCF expended during FY 2022-23 under the Refugee Programs, $6.7 million was provided to subrecipients. Of the $489.9 million DCF expended during FY 2022-23 under the CCDF Cluster, $54.1 million was provided to subrecipients. To determine whether subawards were reported in FSRS in an accurate and timely manner, we reviewed subawards reported in FSRS for two months of FY 2022-23. We interviewed DCF staff to gain an understanding of the procedures for compiling information for subawards and submitting the information in FSRS. We requested subaward agreements and amendments, summary spreadsheets, and reporting information from FSRS for each subaward reviewed.
Questioned Costs:
None.
Effect:
DCF did not comply with FFATA requirements for the timely reporting of subawards in FSRS for the Refugee Programs or CCDF Cluster. The public and interested parties did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the Refugee Programs or the CCDF Cluster.
Cause:
The query DCF used to identify subawards for FFATA reporting did not identify subawards based on the date the subaward was signed. Instead, the query identified subawards for reporting based on the beginning of the period of performance for the subaward. In addition, DCF staff did not consistently input the subawards into the subaward tracking system within the same month the subaward was signed, which then excluded those subawards from being identified in the query.
Recommendation:
We recommend the Department of Children and Families review the query used to determine subawards and its overall procedures for Federal Funding Accountability and Transparency Act (FFATA) reporting and make any needed adjustments to ensure all original subaward agreements and amendments are input and updated in the FFATA Subaward Reporting System in a timely manner.
Finding 2023-202: Multiple Grants—Federal Funding Accountability and Transparency Act Reporting
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendation.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Background:
Subawards of $30,000 or more are subject to FFATA reporting for certain grant programs administered by the State. During FY 2022 23, DEBF was responsible for uploading required FFATA information into FSRS based on information reported by certain state agencies that had identified subawards subject to FFATA reporting. DEBF also provided guidance and technical assistance to agencies on FFATA reporting requirements.
Criteria:
Under 2 CFR s. 170, FFATA reporting is to be submitted no later than the last day of the month following the month in which the creation or the change to a subaward was made. Guidance on FSRS.gov, including a series of frequently asked questions, indicates what is required to be reported. The guidance assists FSRS users in determining when to establish new records based on subaward activity and making modifications to subaward amounts, including when de-obligating funds or when providing new awards that total at least $30,000.
Condition:
When reporting subaward modifications, DEBF reports the cumulative amount of the subaward, not just the modification, in FSRS. However, a state agency that directly submitted FFATA information in FSRS for its own subawards reported only the modified amount when it increased the obligation to subawards that had previously been reported in FSRS. The guidance on FSRS.gov indicates that reporting should be completed each month and that reopening the existing record to report changes would be incorrect. The guidance also indicates that modifications to subawards, such as a de-obligation in the award amount or other corrections, should be made in the original subaward record in FSRS. Finally, the guidance states that the end result of reporting the subaward amounts monthly are that the amounts per subawardee are cumulative of all submitted reports, when considered together. This further indicates that only the modification should be entered into FSRS.
In reviewing subaward information on USASpending.gov for two subawards, we found that for a subaward that DOA reported cumulative amounts for each modification, the total subaward was overstated on USASpending.gov when all entries were considered. However, for the agency that reported only the modification, the total subaward was reported correctly on USASpending.gov.
Context:
DEBF staff were responsible for submitting subaward information in FSRS on behalf of most state agencies, including DOA and the departments of Children and Families, Justice, Natural Resources, and Workforce Development. We discussed DEBF’s procedures for reporting in FSRS, including the information it provided to agencies and how award modifications were reported. We reviewed the frequently asked questions related to FFATA reporting that were provided on FSRS.gov. We reviewed information that state agencies submitted to DOA, and we obtained the related documentation from FSRS for those major programs for which FFATA reporting was subject to audit. As a result, we referenced this finding to the major programs audited for FY 2022-23, for which FFATA reporting was subject to audit and DOA was responsible for FFATA reporting.
Questioned Costs:
None.
Effect:
The amount of subaward obligations reported by state agencies may be misstated on USASpending.gov, which may result in inaccurate information being presented to the public and interested parties.
Cause:
DOA indicated that it relied on guidance it previously obtained from an Office of Management and Budget (OMB) official who indicated cumulative subaward amounts should be used when modifications to subawards are reported in FSRS. However, DOA did not have documentation to support the guidance it obtained. Subsequent to our inquiries, DOA contacted a federal official with OMB in March 2024 to clarify the reporting requirements. At the time of our fieldwork, DOA had not received a response to its inquiry.
Recommendation:
We recommend the Wisconsin Department of Administration:
-alter its approach to report only the amount of the subaward modifications into the FFATA Subaward Reporting System (FSRS) based on the guidance on FSRS.gov;
-update the existing Department of Administration guidance being used by state agencies to provide subaward modifications to the Department of Administration for submission to FSRS;
-provide training to all state agencies to ensure consistent reporting across state agencies; and
-maintain its current approach of reporting cumulative amounts of the subaward only if it receives specific guidance from the Office of Management and Budget indicating that it should report subaward modifications cumulatively.
Finding 2023-106: Multiple Grants—Reporting Subaward Modifications for Federal Funding Accountability and Transparency Act Reporting
Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Numbers Award Years
B-17-DC-55-0001 2017
B-18-DC-55-0001 2018
B-19-DC-55-0001 2019
B-20-C-55-0001 2020
B-19-DV-55-0001 2020
B-21-DC-55-0001 2021
B-22-DC-55-0001 2022
Questioned Costs: None
COVID-19—Community Development Block Grants/State’s program and Non-Entitlement Grants in Hawaii (Assistance Listing number 14.228)
Award Number Award Year
B-20-DW-55-0001 2021
Questioned Costs: None
Crime Victim Assistance (Assistance Listing number 16.575)
Award Numbers Award Years
2019-V2-GX-0045 2019
2020-V2-GX-0009 2020
15POVC-21-GG-00606-ASSI 2021
Questioned Costs: None
Workforce Innovation and Opportunity Act Cluster (Assistance Listing numbers 17.258/17.259/17.278)
Award Numbers Award Years
AA-34803-20-55-A-55 2020
AA-36354-21-55-A-55 2021
AA-38564-22-55-A-55 2022
Questioned Costs: None
Geographic Programs - Great Lakes Restoration Initiative (Assistance Listing number 66.469)
Award Numbers Award Years
00E02349 2018
00E02456 2019
00E02824 2020
00E03149 2022
00E03187 2022
00E03252 2022
00E03010 2022
Questioned Costs: None
COVID-19—Low Income Household Water Assistance Program (Assistance Listing number 93.499)
Award Number Award Year
2101WILWCS 2021
Questioned Costs: None
Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing number 93.566)
Award Numbers Award Years
2101WIRSSS 2021
2201WIRCMA 2022
2201WIRSSS 2022
2301WIRCMA 2023
2301WIRSSS 2023
Questioned Costs: None
Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDD 2022
2340WICCDD 2023
Questioned Costs: None
COVID-19—Child Care and Development Block Grant (Assistance Listing number 93.575)
Award Numbers Award Years
2140WICSC6 2021
2140WICDC6 2021
2140WICCC5 2021
Questioned Costs: None
Child Care Mandatory and Matching Funds of the Child Care and Development Fund (Assistance Listing number 93.596)
Award Numbers Award Years
2140WICCDF 2021
2240WICCDF 2022
2340WICCDF 2023
Questioned Costs: None
Foster Care Title IV-E (Assistance Listing number 93.658)
Award Numbers Award Years
2201WIFOST 2022
2301WIFOST 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Administration: The Wisconsin Department of Administration agrees with the audit finding and recommendations.
Social Services Block Grant—Subrecipient Contracts
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for SSBG. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of the population. During FY 2022-23, DHS provided $9.6 million in SSBG funds to DCF for the children and family aids program, which provides for prevention, investigation, and treatment services related to child abuse and neglect. In addition to general purpose revenue and other federal funds, DCF uses the SSBG funds and contracts with each county for the administration of this program. Because DCF provides funding to counties to carry out the purpose of a federal program, DCF is considered a pass-through entity, and the counties are considered subrecipients.
In establishing contracts, DCF uses specific contract codes within the contract to designate the children and family aids program, the purpose of the program, the costs that will be reimbursed, and the federal programs being used in funding the amount of the contract. The information provided to the subrecipients for each contract code included in the contract, either in the contract or in other referenced information, includes the federal assistance listing number, as appropriate, and other required information. The contract codes for the children and family aids program are then used by the counties when determining which costs may be funded and in requesting reimbursement for costs incurred.
Criteria:
Under 2 CFR s. 200.332, the pass-through entity is required to clearly identify to the subrecipient certain information that allows the subrecipient to understand the federal requirements related to the funding provided. This information includes providing the federal assistance listing number and the amount being provided under the assistance listing number.
Condition:
DCF did not identify in the contracts with the counties that the contract code used for the children and family aids program was partially funding by SSBG. Information such as the assistance listing number and the award amount that was specific to SSBG was not included in the contract or in other information referenced in the contract.
Context:
We reviewed 7 of the 72 county contracts that were entered into during FY 2022-23 and discussed with DCF staff the inclusion of the assistance listing number for the contract codes used for the children and family aids program. During FY 2022-23, DCF subawarded $7.4 million in SSBG funds.
Questioned Costs:
None.
Effect:
Because the contracts with the counties do not include information related to the SSBG program, the counties may be unaware that they have received SSBG funds. This could result in the counties not complying with federal requirements related to SSBG funding.
Cause:
The funds DCF received from DHS were recorded in an appropriation that was designated as program revenue funding. DCF did not have procedures in place to identify the SSBG funds received from DHS for the children and family aids program
as federal funding.
Recommendation:
We recommend the Wisconsin Department of Children and Families:
-inform the counties of any Social Services Block Grant funding provided in subrecipient contracts for the children and family aids program; and
-implement procedures to identify federal funding that is received as a transfer from another state agency when subgranting funds.
Finding 2023-200: Social Services Block Grant—Subrecipient Contracts
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2301WISOSR 2023
2201WISOSR 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Children and Families: The Wisconsin Department of Children and Families agrees with the audit finding and recommendations.
Social Services Block Grant—Subrecipient Contracts
Background:
DHHS provides funding to DHS for the SSBG program. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of the population. In addition, the State can transfer funds received under the Temporary Assistance for Needy Families (TANF) program (Assistance Listing number 93.558) to the SSBG program for use under this program. During FY 2022-23, $14.7 million was transferred to the SSBG program from the TANF program. DHS uses the SSBG funding, including the amounts transferred from the TANF program and general purpose revenue, to provide funding for the community aids program, and more specifically, amounts designated within this program as the “basic county allocation” that can be used by counties to support any eligible service.
DHS contracts with each county for the administration of the community aids program. Because DHS provides funding to counties to carry out the purpose of a federal program, DHS is considered a pass-through entity, and the counties are considered subrecipients. DHS uses its Community Aids Reporting System (CARS) and establishes CARS profiles to designate the program, the purpose of the program, the types of costs that will be reimbursed, and the federal programs that are used in funding the amount of the contract. The information provided to the counties for a CARS profile will include the federal assistance listing number, as appropriate, and other required information. The CARS profile established for the basic county allocation is used by the counties when determining costs that can be funded and in requesting reimbursement for costs incurred.
Criteria:
Under 2 CFR s. 200.332, the pass-through entity is required to clearly identify to the subrecipient certain information that allows the subrecipient to understand the federal requirements related to the funding provided. This information includes providing the federal assistance listing number and the amount being provided under the assistance listing number.
42 USC section 604 allows for the transfer of funds from the TANF program to the SSBG program. Once transferred, the funding is no longer considered TANF funding and is subject to the requirements that apply to the SSBG program. Further, expenditures incurred with the transferred TANF funds would be considered an expenditure of SSBG.
Condition:
In the contracts with the counties, DHS identified that both the SSBG and TANF programs were being used to provide funding for the CARS profile for the basic county allocation. The TANF funds transferred to SSBG are subject to the requirements of the SSBG program, but the information DHS provided to the counties, which included the assistance listing number, inaccurately identified the TANF program as a funding source.
Context:
We reviewed 7 of the 72 county contracts that were executed during FY 2022-23 and discussed with DHS staff the inclusion of the assistance listing number for the CARS profile used for the basic county allocation. During FY 2022-23, DHS expended $33.4 million in SSBG funds, which included transferred TANF funds, and subawarded $32.4 million.
Questioned Costs:
None.
Effect:
Because the contracts with the counties did not accurately identify the transferred TANF funds as those from the SSBG program, the counties were not aware of the full amount of SSBG funds received and as a result may not be aware of the federal requirements related to this funding. This could result in the counties not complying with federal requirements related to the SSBG funding.
Cause:
In contract development, DHS separately identified the SSBG and transferred TANF funds used in funding the basic county allocation. This separation resulted in the error in identifying TANF as a funding source in the contracts with the counties.
Recommendation:
We recommend the Wisconsin Department of Health Services update its procedures for contract development to ensure information provided in its subrecipient contracts identified the Social Services Block Grant as the federal funding source for the basic county allocation of the community aids program related to the transferred Temporary Assistance for Needy Families funds.
Finding 2023-301: Social Services Block Grant—Subrecipient Contracts
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2301WISOSR 2023
2201WISOSR 2022
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendation.
Social Services Block Grant—FFATA Reporting
Background:
DHHS provides funding to DHS for the SSBG program. This program provides flexible financial assistance to states that allows states to tailor social services programs to the needs of the population. In addition to general purpose revenue, DHS uses the SSBG funds for the basic county allocation of the community aids program, and it subawards amounts to each county for the administration of this program. DHS also transfers SSBG funds to the Wisconsin Department of Children and Families (DCF). DCF uses the SSBG funds, in addition to other federal funds and general purpose revenue, for the children and family aids program, and it subawards amounts to each county for the administration of this program.
Criteria:
Under 2 CFR s. 170, and as the prime grant awardee for the SSBG program, DHS has overall responsibility for Federal Funding Accountability and Transparency Act (FFATA) reporting and is required to report in the FFATA Subaward Reporting System (FSRS) subawards of $30,000 or more, including any amendments or modifications to a subaward. This reporting is to be submitted no later than the last day of the month following the month in which the creation or change to the subaward was made. For example, if a subaward was made on December 15, 2022, it must be reported no later than January 31, 2023.
Condition:
During FY 2022-23, both DHS and DCF made subawards of $30,000 or more in SSBG funds to counties. DHS did not report any SSBG-funded subawards in FSRS.
Context:
During FY 2022-23, DHS expended $33.4 million in SSBG funds of which $32.4 million was provided to subrecipients. During FY 2022-23, DCF expended $9.6 million, of which $7.4 million was provided to subrecipients. We interviewed DHS staff to gain an understanding of the SSBG program, the use of the funds, and procedures for compiling and reviewing subaward information, and submitting this information in FSRS.
Questioned Costs:
None.
Effect:
The State’s stakeholders and the public did not have access to transparent and timely information about the federal award spending decisions on USASpending.gov for the SSBG program. DHS did not comply with FFATA requirements for the reporting of subawards for the SSBG program.
Cause:
For the subgrants provided under the basic county allocation of the community aids program, DHS initially recorded payments of the amounts it subawarded to counties to a general purpose revenue appropriation. As a result, these subawards were not identified in the reports DHS used to determine FFATA reporting. In addition, DHS did not have procedures in place to obtain information related to the subgrants provided by DCF or to determine whether responsibility for FFATA reporting could be delegated to DCF.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-revise its procedures for Federal Funding Accountability and Transparency Act reporting to ensure all subawards funded by federal grants are included in reports used to identify subawards for reporting; and
-develop procedures to identify and report subawards made by the state agencies to which it has transferred federal funding.
Finding 2023-302: Social Services Block Grant—FFATA Reporting
Social Services Block Grant (Assistance Listing number 93.667)
Award Numbers Award Years
2301WISOSR 2023
2201WISOSR 2022
Questioned Costs: None
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the reporting compliance requirement.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding health care coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced federal medical assistance percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a post-partum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants. DHS also closed certain CHIP and MA cases in the CARES system and continued benefit payments through MMIS.
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under an SCHIP program to participants who did not meet age requirements. At the time participants reached age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, it further stated that changes in circumstances described in 42 s. CFR 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19. Benefits for these participants were maintained either by maintaining eligibility for the participant in the CARES system or by closing the participant’s case in the CARES system and continuing benefit payments for the participant through MMIS.
During our audit, we identified 8,996 SCHIP participants in the CARES system who were age 19 or older as of June 30, 2023. Of these participants, 3,695 were age 19 as of April 30, 2023, 4,578 participants were over age 19 as of April 30, 2023, and 723 participants turned age 19 during May or June 2023.
In a separate analysis, we also identified 1,372 participants who were age 19 or older as of July 1, 2022, who received SCHIP benefits paid through MMIS during FY 2022-23. These participants did not have an open CHIP case in the CARES system for FY 2022-23.
Context:
During FY 2022-23, DHS expended $253.1 million in federal funds under CHIP, including approximately $150.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 81,243 participants identified in the CARES system as an open case in SCHIP between July 2022 and April 2023. From this listing, we identified 8,273 participants who were age 19 or older as of April 30, 2023, and 723 participants who turned age 19 in May and June 2023. We further reviewed detailed FY 2022-23 payments made to managed care organizations and payments made to providers paid on a fee-for-service basis. Using the recipient IDs for the 8,996 participants who were age 19 or older, we calculated total payments to providers identified as costs that were funded by SCHIP.
To identify participants who continued to receive benefits paid directly through MMIS but who did not have an open CHIP case in the CARES system, we reviewed detailed FY 2022-23 payments from MMIS and identified participants who were age 19 or older as of July 1, 2022, who were provided benefits that were identified as being funded by SCHIP. We compared this listing of participants to the listing of participants identified as having an open CHIP case in the CARES system and identified 1,372 participants who were age 19 or older as of July 1, 2022, that were receiving benefits during FY 2022-23 but were not included in the listing of open CHIP cases in the CARES system.
Questioned Costs:
We reviewed detailed FY 2022-23 payment information for the 8,996 SCHIP participants who were age 19 or older, and we identified $16,682,899 in benefits that were provided to them during FY 2022-23. Using the weighted average of the FMAP
in effect for federal fiscal year (FFY) 2022 and FFY 2023 (72.03 percent) and the average temporary increase to the FMAP for FY 2022-23 (4.13 percent), we question $12,706,113, representing the federal share of these payments. We also question an undetermined amount for benefits provided to other ineligible SCHIP participants who continued to receive benefits through MMIS, but were age 19 or older as of July 1, 2022.
Effect:
We identified that DHS made improper payments and received federal reimbursement for participants who were ineligible for SCHIP.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS nor result in system changes to CARES.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. DHS is expected to complete redeterminations of all participants in MA and CHIP by June 2024, which is the end of the unwinding period, and it has stated that CHIP participants who exceeded the age requirement for the program have been prioritized.
Recommendation:
We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate.
Finding 2023-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $12,017,109, Plus an Undetermined Amount
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $689,004, Plus an Undetermined Amount
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees conceptually with the finding, however, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program.
Legislative Audit Bureau Rebuttal: As stated in the finding, and as acknowledged by DHS, DHS maintained continuous eligibility for SCHIP participants who were over age 19. This eligibility requirement continued through the public health emergency. Since CHIP and Medicaid are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the Medicaid program.
Eligibility for the Children’s Health Insurance Program
Background:
The U.S. Department of Health and Human Services (DHHS) provides funding to DHS for CHIP. Funding under this program provides financial assistance to states in maintaining and expanding health care coverage to children residing in low-income families. CHIP is funded by both the state and federal government, with the federal portion determined by the enhanced federal medical assistance percentage (FMAP) rate. Under CHIP, Wisconsin has a separate CHIP program (SCHIP) that provides health insurance to uninsured low-income children as well as certain pregnant women through a post-partum period. Also under CHIP, Wisconsin has a Medicaid expansion program (MCHIP) that expands the State’s MA program and provides enhanced federal participation for targeted low-income children.
DHS partners with local agency caseworkers who are responsible for verifying that CHIP participants meet program eligibility requirements. Caseworkers perform eligibility determination functions, such as obtaining information from the parents or guardians of children applying for health care benefits that is then recorded into the Client Assistance for Reemployment and Economic Support (CARES) system. DHS relies on the CARES system to manage CHIP cases to ensure only eligible participants receive CHIP benefits. Information from the CARES system related to eligible participants is then used by the Medicaid Management Information System (MMIS) to process payments to providers and managed care organizations. During the public health emergency, the federal government required a continuous eligibility period for MA participants. DHS also closed certain CHIP and MA cases in the CARES system and continued benefit payments through MMIS.
Criteria:
Title XXI of the Social Security Act permits states to establish certain eligibility criteria for CHIP. Per 42 CFR s. 457.320, and following guidelines set forth in 42 USC s. 1397bb (b), DHS established age criteria that permits children under 19 years of age to participate in SCHIP. As a condition of receiving a temporary increase to federal participation under the Families First Coronavirus Response Act, states were required to maintain enrollment of nearly all eligible MA participants. Although this requirement applied to participants determined eligible for MCHIP, it did not apply to SCHIP participants. In guidance issued in January 2021, the Centers for Medicare and Medicaid Services (CMS) further specified that states should not continue to provide coverage under an SCHIP program to participants who did not meet age requirements. At the time participants reached age 19, the guidance specifies that states should transition the participant from SCHIP coverage to MA coverage, if eligible.
In response to the public health emergency, DHS also received approval from CMS on August 19, 2020, for an amendment to SCHIP that allowed the State to delay acting on certain changes, beginning March 1, 2020. However, it further stated that changes in circumstances described in 42 s. CFR 457.342 (a) and cross-referenced to 42 CFR s. 935.926 (d) should continue to be acted on, including the circumstance of a child attaining the age of 19.
Condition:
During the public health emergency, and in conflict with federal requirements and the approved state plan, DHS maintained continuous eligibility for SCHIP participants who were over age 19. Benefits for these participants were maintained either by maintaining eligibility for the participant in the CARES system or by closing the participant’s case in the CARES system and continuing benefit payments for the participant through MMIS.
During our audit, we identified 8,996 SCHIP participants in the CARES system who were age 19 or older as of June 30, 2023. Of these participants, 3,695 were age 19 as of April 30, 2023, 4,578 participants were over age 19 as of April 30, 2023, and 723 participants turned age 19 during May or June 2023.
In a separate analysis, we also identified 1,372 participants who were age 19 or older as of July 1, 2022, who received SCHIP benefits paid through MMIS during FY 2022-23. These participants did not have an open CHIP case in the CARES system for FY 2022-23.
Context:
During FY 2022-23, DHS expended $253.1 million in federal funds under CHIP, including approximately $150.5 million in federal funds expended to provide benefits to participants under SCHIP.
DHS provided a listing of 81,243 participants identified in the CARES system as an open case in SCHIP between July 2022 and April 2023. From this listing, we identified 8,273 participants who were age 19 or older as of April 30, 2023, and 723 participants who turned age 19 in May and June 2023. We further reviewed detailed FY 2022-23 payments made to managed care organizations and payments made to providers paid on a fee-for-service basis. Using the recipient IDs for the 8,996 participants who were age 19 or older, we calculated total payments to providers identified as costs that were funded by SCHIP.
To identify participants who continued to receive benefits paid directly through MMIS but who did not have an open CHIP case in the CARES system, we reviewed detailed FY 2022-23 payments from MMIS and identified participants who were age 19 or older as of July 1, 2022, who were provided benefits that were identified as being funded by SCHIP. We compared this listing of participants to the listing of participants identified as having an open CHIP case in the CARES system and identified 1,372 participants who were age 19 or older as of July 1, 2022, that were receiving benefits during FY 2022-23 but were not included in the listing of open CHIP cases in the CARES system.
Questioned Costs:
We reviewed detailed FY 2022-23 payment information for the 8,996 SCHIP participants who were age 19 or older, and we identified $16,682,899 in benefits that were provided to them during FY 2022-23. Using the weighted average of the FMAP
in effect for federal fiscal year (FFY) 2022 and FFY 2023 (72.03 percent) and the average temporary increase to the FMAP for FY 2022-23 (4.13 percent), we question $12,706,113, representing the federal share of these payments. We also question an undetermined amount for benefits provided to other ineligible SCHIP participants who continued to receive benefits through MMIS, but were age 19 or older as of July 1, 2022.
Effect:
We identified that DHS made improper payments and received federal reimbursement for participants who were ineligible for SCHIP.
Cause:
To comply with continuous eligibility requirements, DHS indicated that various changes were made to the CARES system at the start of the public health emergency to ensure that changes in circumstances did not result in terminations unless the member passed away, moved out of state, or voluntarily requested disenrollment. These changes were applied to all MA programs, including programs funded through CHIP. DHS indicated that it chose to maintain continuous eligibility for participants in SCHIP to prioritize and protect the health and safety of the children covered by the program from the loss of access to coverage. DHS indicated that further changes to the CARES system were not pursued in response to the January 2021 CMS guidance.
DHS indicated that as the public health emergency continued, it focused on preparing for the end of the public health emergency. In addition, DHS informed us that discussions with CMS in May 2022 related to concerns with compliance and system limitations did not result in further follow-up from CMS nor result in system changes to CARES.
The unwinding period, which began on April 1, 2023, is the period after the expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act, and includes the process of resuming to normal operations, including restarting full MA and CHIP eligibility renewals and terminations of coverage for ineligible individuals. DHS is expected to complete redeterminations of all participants in MA and CHIP by June 2024, which is the end of the unwinding period, and it has stated that CHIP participants who exceeded the age requirement for the program have been prioritized.
Recommendation:
We recommend the Wisconsin Department of Health Services work with the federal government to resolve these improper payments, including the determination of the total amount of improper payments, and return these amounts to the federal government, as appropriate.
Finding 2023-300: Eligibility for the Children’s Health Insurance Program
Children’s Health Insurance Program (Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $12,017,109, Plus an Undetermined Amount
COVID-19—Children’s Health Insurance Program
(Assistance Listing number 93.767)
Award Numbers Award Years
2205WI15021 2022
2305WI15021 2023
Questioned Costs: $689,004, Plus an Undetermined Amount
Type of Finding: Material Weakness, Material Noncompliance
As a result, we qualified our opinion on compliance for the activities allowed or unallowed, allowable costs/cost principles, and eligibility compliance requirements.
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees conceptually with the finding, however, the questioned costs identified do not consider that many (if not most) of the ineligible members would have been eligible for Medicaid as childless adults upon aging out of the CHIP program.
Legislative Audit Bureau Rebuttal: As stated in the finding, and as acknowledged by DHS, DHS maintained continuous eligibility for SCHIP participants who were over age 19. This eligibility requirement continued through the public health emergency. Since CHIP and Medicaid are separate programs, consideration of whether these participants could have been eligible for the Medicaid program would not have been part of our audit. Payments to providers for these participants were funded by SCHIP and not the Medicaid program.
Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Background:
DHHS provides funding to DHS for the MA Program (Assistance Listing number 93.778). Funding under the MA Program is used to assist states in providing health care services to certain categories of low-income persons. Under the MA Program, a state may obtain a waiver to provide home- and community-based services. Such a waiver may permit an individual to receive services in their own home or community rather than in an institutional care setting. Under 1915 (c) of the Social Security Act, Wisconsin has an approved waiver to administer the Include, Respect, I Self-Direct (IRIS) program. This program provides services to MA-eligible adults that facilitates participant choice, direction, and control over home- and community-based services. The current IRIS waiver approved by CMS is effective from January 1, 2021, through December 31, 2025.
During FY 2022-23, DHS contracted with six independent consulting agencies (ICAs) that assisted IRIS participants in developing individual support and service plans to meet each participant’s needs within the participant’s approved IRIS annual budget. DHS also contracted with four fiscal employer agents (FEAs) that are responsible for receiving invoices for services provided to participants, reviewing the invoices in accordance with the approved individual support and service plan, and for paying the invoice, when it is aligned with the approved plan. The FEA submits information to DHS related to the approved payments, and DHS makes funds available to enable the FEA to make the payments. On a monthly basis, the FEA is also required to submit through the DHS Encounter system participant-specific data of the detailed services provided.
Criteria:
As required by 42 CFR Part 441.303 (b), the approved waiver for the IRIS program outlines several financial integrity and accountability oversight activities to be performed by DHS. These oversight activities provide assurances related to the financial integrity and accountability of funds expended for home- and community-based services under the IRIS program. Under 42 CFR Part 441.302 and 441.302 (b), CMS may terminate an already granted waiver if an agency does not assure the financial accountability of funds expended for home- and community-based services.
Condition:
Based upon our review of selected financial integrity and accountability oversight activities included in the approved waiver, we found that DHS performed some but not all of the oversight activities. For example, DHS required each ICA and FEA to have an annual independent third-party financial audit performed, which DHS was to obtain and review. However, we identified that during FY 2022-23 DHS had not performed certain financial integrity and accountability oversight activities outlined in the approved waiver, including:
-completing an audit of 20 percent of the claims exceeding $2,500 or more that were received in biweekly claims files submitted for payment from the FEA; and
-completing a data integrity audit to review the detailed participant data submitted by the FEAs through the DHS Encounter system, including reviewing this data for accuracy and compliance with claim submission standards and source data authorizations, such as the service provided, the frequency of services, the authorization period, and the date of service.
Context:
During FY 2022-23, DHS provided $8.1 billion in benefit payments to participants in the MA Program. Payments for care or services provided to IRIS participants was $585.1 million of this amount. We reviewed the IRIS waiver to identify the financial integrity and accountability oversight activities DHS staff stated that they would perform to provide the required assurances. For selected financial integrity and accountability oversight activities outlined within the waiver, we conducted inquiries of DHS staff to determine if these activities had been performed.
Questioned Costs:
None.
Effect:
DHS did not comply with all financial integrity and accountability oversight activities included in the approved waiver and, therefore, did not have the assurance that these oversight activities could provide. In addition, because DHS did not perform all financial integrity and accountability oversight activities, it is at risk for the waiver to be terminated.
Cause:
DHS did not have procedures in place to perform the financial integrity and accountability oversight activities included in the approved waiver. DHS reported that in a prior year it had performed an assessment of the amount of work required
to complete the oversight activities included in the approved waiver and determined it would be infeasible. However, DHS did not take steps to document alternative oversight activities that would meet the objective to provide financial integrity and accountability oversight or seek an amendment to the waiver.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-implement the financial integrity and accountability oversight activities in its approved waiver; or
-determine if alternative oversight activities that meet the objective to provide financial integrity and accountability oversight can be performed; and
-work with the federal government to determine whether an amendment to its current waiver is needed.
Finding 2023-303: Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2305WI5MAP 2023
Questioned Costs: None
COVID-19—Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2205WI5MAP 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.
Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Background:
DHHS provides funding to DHS for the MA Program (Assistance Listing number 93.778). Funding under the MA Program is used to assist states in providing health care services to certain categories of low-income persons. Under the MA Program, a state may obtain a waiver to provide home- and community-based services. Such a waiver may permit an individual to receive services in their own home or community rather than in an institutional care setting. Under 1915 (c) of the Social Security Act, Wisconsin has an approved waiver to administer the Include, Respect, I Self-Direct (IRIS) program. This program provides services to MA-eligible adults that facilitates participant choice, direction, and control over home- and community-based services. The current IRIS waiver approved by CMS is effective from January 1, 2021, through December 31, 2025.
During FY 2022-23, DHS contracted with six independent consulting agencies (ICAs) that assisted IRIS participants in developing individual support and service plans to meet each participant’s needs within the participant’s approved IRIS annual budget. DHS also contracted with four fiscal employer agents (FEAs) that are responsible for receiving invoices for services provided to participants, reviewing the invoices in accordance with the approved individual support and service plan, and for paying the invoice, when it is aligned with the approved plan. The FEA submits information to DHS related to the approved payments, and DHS makes funds available to enable the FEA to make the payments. On a monthly basis, the FEA is also required to submit through the DHS Encounter system participant-specific data of the detailed services provided.
Criteria:
As required by 42 CFR Part 441.303 (b), the approved waiver for the IRIS program outlines several financial integrity and accountability oversight activities to be performed by DHS. These oversight activities provide assurances related to the financial integrity and accountability of funds expended for home- and community-based services under the IRIS program. Under 42 CFR Part 441.302 and 441.302 (b), CMS may terminate an already granted waiver if an agency does not assure the financial accountability of funds expended for home- and community-based services.
Condition:
Based upon our review of selected financial integrity and accountability oversight activities included in the approved waiver, we found that DHS performed some but not all of the oversight activities. For example, DHS required each ICA and FEA to have an annual independent third-party financial audit performed, which DHS was to obtain and review. However, we identified that during FY 2022-23 DHS had not performed certain financial integrity and accountability oversight activities outlined in the approved waiver, including:
-completing an audit of 20 percent of the claims exceeding $2,500 or more that were received in biweekly claims files submitted for payment from the FEA; and
-completing a data integrity audit to review the detailed participant data submitted by the FEAs through the DHS Encounter system, including reviewing this data for accuracy and compliance with claim submission standards and source data authorizations, such as the service provided, the frequency of services, the authorization period, and the date of service.
Context:
During FY 2022-23, DHS provided $8.1 billion in benefit payments to participants in the MA Program. Payments for care or services provided to IRIS participants was $585.1 million of this amount. We reviewed the IRIS waiver to identify the financial integrity and accountability oversight activities DHS staff stated that they would perform to provide the required assurances. For selected financial integrity and accountability oversight activities outlined within the waiver, we conducted inquiries of DHS staff to determine if these activities had been performed.
Questioned Costs:
None.
Effect:
DHS did not comply with all financial integrity and accountability oversight activities included in the approved waiver and, therefore, did not have the assurance that these oversight activities could provide. In addition, because DHS did not perform all financial integrity and accountability oversight activities, it is at risk for the waiver to be terminated.
Cause:
DHS did not have procedures in place to perform the financial integrity and accountability oversight activities included in the approved waiver. DHS reported that in a prior year it had performed an assessment of the amount of work required
to complete the oversight activities included in the approved waiver and determined it would be infeasible. However, DHS did not take steps to document alternative oversight activities that would meet the objective to provide financial integrity and accountability oversight or seek an amendment to the waiver.
Recommendation:
We recommend the Wisconsin Department of Health Services:
-implement the financial integrity and accountability oversight activities in its approved waiver; or
-determine if alternative oversight activities that meet the objective to provide financial integrity and accountability oversight can be performed; and
-work with the federal government to determine whether an amendment to its current waiver is needed.
Finding 2023-303: Medical Assistance Program—IRIS Financial Integrity and Accountability Oversight Activities
Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2305WI5MAP 2023
Questioned Costs: None
COVID-19—Medical Assistance Program (Assistance Listing number 93.778)
Award Numbers Award Years
2205WI5MAP 2022
2205WI5MAP 2023
Questioned Costs: None
Type of Finding: Significant Deficiency, Noncompliance
Response from the Wisconsin Department of Health Services: The Wisconsin Department of Health Services agrees with the audit finding and recommendations.