2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023)
Pass through Entity Michigan Department of Health and Human Services
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t.
Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year.
Questioned Costs $806
Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services.
Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500.
Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year.
Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually.
Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023)
Pass through Entity Michigan Department of Health and Human Services
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t.
Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year.
Questioned Costs $806
Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services.
Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500.
Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year.
Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually.
Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023)
Pass through Entity Michigan Department of Health and Human Services
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t.
Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year.
Questioned Costs $806
Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services.
Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500.
Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year.
Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually.
Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 003 Assistance Listing, Federal Agency, and Program Name ALN 21.027, COVID 19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)
Federal Award Identification Number and Year SLT 1765, 2021, SLFRP0127, 2023, and 38 6004849, 2023
Pass through Entity Michigan Department of Natural Resources and State Court Administrative Office
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 001
Criteria The County should ensure there is a process in place, prior to entering contracts with vendors, to verify that such vendors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition We noted during testing that the County had no procedures in place to verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with CSLFRF funds.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, the County had 12 conractors with which the County had active contracts using Coronavirus State and Local Fiscal Recovery Fund funding that should have been verified to ensure tha they were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. We selected two new contracts entered into during the current year for testing, and both lacked verification, contract clause or certification from contractor. However, once Plante Moran identified this issue, the County performed procedures to ensure contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, and Plante Moran audited those results, thereby creating no questioned costs.
Cause and Effect The County did not have a control in place to verify that any contractor with which it plans to enter into a contract using Coronavirus State and Local Fiscal Recovery Fund is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The County could have entered into a contract with vendors that were suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Upon verifying the contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 after the contracts were in place, no questioned costs were present.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure the verification of contractors occurs before contractors are awarded Coronavirus State and Local Fiscal Recovery Fund contracts.
Views of Responsible Officials and Planned Corrective Actions During fiscal year 2022, the County staff checked the suspension and debarment listing but did not print the screen for audit documentation. This finding was identified last year when the County had already had some time pass during fiscal year 2023. A procedure was put in place at the point that contracts are submitted to the Board of Commissioners for approval to print the documentation and attach it that shows the contractor is not included on the suspended and debarred listing.
2023 003 Assistance Listing, Federal Agency, and Program Name ALN 21.027, COVID 19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)
Federal Award Identification Number and Year SLT 1765, 2021, SLFRP0127, 2023, and 38 6004849, 2023
Pass through Entity Michigan Department of Natural Resources and State Court Administrative Office
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 001
Criteria The County should ensure there is a process in place, prior to entering contracts with vendors, to verify that such vendors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition We noted during testing that the County had no procedures in place to verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with CSLFRF funds.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, the County had 12 conractors with which the County had active contracts using Coronavirus State and Local Fiscal Recovery Fund funding that should have been verified to ensure tha they were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. We selected two new contracts entered into during the current year for testing, and both lacked verification, contract clause or certification from contractor. However, once Plante Moran identified this issue, the County performed procedures to ensure contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, and Plante Moran audited those results, thereby creating no questioned costs.
Cause and Effect The County did not have a control in place to verify that any contractor with which it plans to enter into a contract using Coronavirus State and Local Fiscal Recovery Fund is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The County could have entered into a contract with vendors that were suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Upon verifying the contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 after the contracts were in place, no questioned costs were present.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure the verification of contractors occurs before contractors are awarded Coronavirus State and Local Fiscal Recovery Fund contracts.
Views of Responsible Officials and Planned Corrective Actions During fiscal year 2022, the County staff checked the suspension and debarment listing but did not print the screen for audit documentation. This finding was identified last year when the County had already had some time pass during fiscal year 2023. A procedure was put in place at the point that contracts are submitted to the Board of Commissioners for approval to print the documentation and attach it that shows the contractor is not included on the suspended and debarred listing.
2023 003 Assistance Listing, Federal Agency, and Program Name ALN 21.027, COVID 19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)
Federal Award Identification Number and Year SLT 1765, 2021, SLFRP0127, 2023, and 38 6004849, 2023
Pass through Entity Michigan Department of Natural Resources and State Court Administrative Office
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 001
Criteria The County should ensure there is a process in place, prior to entering contracts with vendors, to verify that such vendors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition We noted during testing that the County had no procedures in place to verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with CSLFRF funds.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, the County had 12 conractors with which the County had active contracts using Coronavirus State and Local Fiscal Recovery Fund funding that should have been verified to ensure tha they were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. We selected two new contracts entered into during the current year for testing, and both lacked verification, contract clause or certification from contractor. However, once Plante Moran identified this issue, the County performed procedures to ensure contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, and Plante Moran audited those results, thereby creating no questioned costs.
Cause and Effect The County did not have a control in place to verify that any contractor with which it plans to enter into a contract using Coronavirus State and Local Fiscal Recovery Fund is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The County could have entered into a contract with vendors that were suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Upon verifying the contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 after the contracts were in place, no questioned costs were present.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure the verification of contractors occurs before contractors are awarded Coronavirus State and Local Fiscal Recovery Fund contracts.
Views of Responsible Officials and Planned Corrective Actions During fiscal year 2022, the County staff checked the suspension and debarment listing but did not print the screen for audit documentation. This finding was identified last year when the County had already had some time pass during fiscal year 2023. A procedure was put in place at the point that contracts are submitted to the Board of Commissioners for approval to print the documentation and attach it that shows the contractor is not included on the suspended and debarred listing.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC)
N/A (Food Distribution)
Pass through Entity Michigan Department of Health and Human Services (WIC)
Michigan Department of Education (Food Distribution)
Finding Type Material weakness
Repeat Finding No
Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l).
Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program.
Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility.
Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information.
Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review.
Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023)
Pass through Entity Michigan Department of Health and Human Services
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t.
Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year.
Questioned Costs $806
Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services.
Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500.
Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year.
Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually.
Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023)
Pass through Entity Michigan Department of Health and Human Services
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t.
Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year.
Questioned Costs $806
Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services.
Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500.
Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year.
Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually.
Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 002 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023)
Pass through Entity Michigan Department of Health and Human Services
Finding Type Significant deficiency
Repeat Finding No
Criteria Per 2 CFR section 200.305(b)(9), interest earned amounts up to $500 per year may be retained by the non Federal entity for administrative expense. Any additional interest earned on Federal advanced payments deposited in interest bearing accounts must be remitted annually to the Department of Health and Human Services Payment Management System (PMS)t.
Condition The County did not track WIC interest income earned throughout the fiscal year, resulting in the County not refunding the Department of Health and Human Services the excess of $500 earned during the year.
Questioned Costs $806
Identification of How Questioned Costs Were Computed The County determined that there was $1,306 of interest earned, less $500 that can be retained for administrative expense, results in $806 that should have been remitted back to the Department of Health and Human Services.
Context From October 1, 2022 through September 30, 2023, the County received advanced payments for the WIC program, which were held in an interest bearing account and those funds earned interest in excess of $500.
Cause and Effect The County did not have a control in place to track the interest earned on WIC advanced payments to note if they exceeded $500 throughout the year. This resulted in the County not properly remitting the excess interest amount earned back to the Department of Health and Human Services at the end of the fiscal year.
Recommendation We recommend that an internal control be put in place to monitor interest earned monthly or quarterly, to ensure that if it exceeds $500 on WIC advance payments, that it is properly remitted back to the Department of Health and Human Resources annually.
Views of Responsible Officials and Planned Corrective Actions The financial analyst assigned to the grant will review interest income earned throughout the fiscal year and ensure any amount exceeding $500 is returned to the Department of Health and Human Services.
2023 003 Assistance Listing, Federal Agency, and Program Name ALN 21.027, COVID 19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)
Federal Award Identification Number and Year SLT 1765, 2021, SLFRP0127, 2023, and 38 6004849, 2023
Pass through Entity Michigan Department of Natural Resources and State Court Administrative Office
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 001
Criteria The County should ensure there is a process in place, prior to entering contracts with vendors, to verify that such vendors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition We noted during testing that the County had no procedures in place to verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with CSLFRF funds.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, the County had 12 conractors with which the County had active contracts using Coronavirus State and Local Fiscal Recovery Fund funding that should have been verified to ensure tha they were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. We selected two new contracts entered into during the current year for testing, and both lacked verification, contract clause or certification from contractor. However, once Plante Moran identified this issue, the County performed procedures to ensure contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, and Plante Moran audited those results, thereby creating no questioned costs.
Cause and Effect The County did not have a control in place to verify that any contractor with which it plans to enter into a contract using Coronavirus State and Local Fiscal Recovery Fund is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The County could have entered into a contract with vendors that were suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Upon verifying the contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 after the contracts were in place, no questioned costs were present.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure the verification of contractors occurs before contractors are awarded Coronavirus State and Local Fiscal Recovery Fund contracts.
Views of Responsible Officials and Planned Corrective Actions During fiscal year 2022, the County staff checked the suspension and debarment listing but did not print the screen for audit documentation. This finding was identified last year when the County had already had some time pass during fiscal year 2023. A procedure was put in place at the point that contracts are submitted to the Board of Commissioners for approval to print the documentation and attach it that shows the contractor is not included on the suspended and debarred listing.
2023 003 Assistance Listing, Federal Agency, and Program Name ALN 21.027, COVID 19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)
Federal Award Identification Number and Year SLT 1765, 2021, SLFRP0127, 2023, and 38 6004849, 2023
Pass through Entity Michigan Department of Natural Resources and State Court Administrative Office
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 001
Criteria The County should ensure there is a process in place, prior to entering contracts with vendors, to verify that such vendors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition We noted during testing that the County had no procedures in place to verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with CSLFRF funds.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, the County had 12 conractors with which the County had active contracts using Coronavirus State and Local Fiscal Recovery Fund funding that should have been verified to ensure tha they were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. We selected two new contracts entered into during the current year for testing, and both lacked verification, contract clause or certification from contractor. However, once Plante Moran identified this issue, the County performed procedures to ensure contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, and Plante Moran audited those results, thereby creating no questioned costs.
Cause and Effect The County did not have a control in place to verify that any contractor with which it plans to enter into a contract using Coronavirus State and Local Fiscal Recovery Fund is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The County could have entered into a contract with vendors that were suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Upon verifying the contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 after the contracts were in place, no questioned costs were present.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure the verification of contractors occurs before contractors are awarded Coronavirus State and Local Fiscal Recovery Fund contracts.
Views of Responsible Officials and Planned Corrective Actions During fiscal year 2022, the County staff checked the suspension and debarment listing but did not print the screen for audit documentation. This finding was identified last year when the County had already had some time pass during fiscal year 2023. A procedure was put in place at the point that contracts are submitted to the Board of Commissioners for approval to print the documentation and attach it that shows the contractor is not included on the suspended and debarred listing.
2023 003 Assistance Listing, Federal Agency, and Program Name ALN 21.027, COVID 19 Coronavirus State and Local Fiscal Recovery Fund (CSLFRF)
Federal Award Identification Number and Year SLT 1765, 2021, SLFRP0127, 2023, and 38 6004849, 2023
Pass through Entity Michigan Department of Natural Resources and State Court Administrative Office
Finding Type Material weakness and material noncompliance with laws and regulations
Repeat Finding Yes
2022 001
Criteria The County should ensure there is a process in place, prior to entering contracts with vendors, to verify that such vendors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300.
Condition We noted during testing that the County had no procedures in place to verify and maintain support for verification that contractors are not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 prior to entering into contracts with CSLFRF funds.
Questioned Costs None
Identification of How Questioned Costs Were Computed Not applicable
Context From October 1, 2022 through September 30, 2023, the County had 12 conractors with which the County had active contracts using Coronavirus State and Local Fiscal Recovery Fund funding that should have been verified to ensure tha they were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. We selected two new contracts entered into during the current year for testing, and both lacked verification, contract clause or certification from contractor. However, once Plante Moran identified this issue, the County performed procedures to ensure contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300, and Plante Moran audited those results, thereby creating no questioned costs.
Cause and Effect The County did not have a control in place to verify that any contractor with which it plans to enter into a contract using Coronavirus State and Local Fiscal Recovery Fund is not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. The County could have entered into a contract with vendors that were suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300. Upon verifying the contractors were not suspended, debarred, or otherwise excluded pursuant to 2 CFR Section 180.300 after the contracts were in place, no questioned costs were present.
Reference Number Finding
Recommendation We recommend that an internal control be put in place to ensure the verification of contractors occurs before contractors are awarded Coronavirus State and Local Fiscal Recovery Fund contracts.
Views of Responsible Officials and Planned Corrective Actions During fiscal year 2022, the County staff checked the suspension and debarment listing but did not print the screen for audit documentation. This finding was identified last year when the County had already had some time pass during fiscal year 2023. A procedure was put in place at the point that contracts are submitted to the Board of Commissioners for approval to print the documentation and attach it that shows the contractor is not included on the suspended and debarred listing.