Federal Agency: United States Department of Agriculture Food and Nutrition Service ALN: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Pass-Through Grantor: State of Wisconsin Department of Health Services – Wisconsin Department of Health and Family Services Pass-Through Award Number: 154710 Pass-Through Award Period: 1/1/2024 to 12/31/2024 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the following eligibility criteria (7 CFR Sections 246.7(c), (d), (e), (g), and (l)): (a) Categorical – Eligibility is restricted to pregnant, postpartum and breastfeeding women; infants; and children up to their fifth birthday (7 CFR Sections 246.2 (definition of each category) and 246.7(c)). (b) Identity and Residency – Except in limited circumstances, WIC applicants must be physically present for eligibility screenings and must provide proof of identity. An applicant must also meet the state agency residency requirement. Except in the case of Indian state agencies, the applicant must reside in the jurisdiction of the state. Indian state agencies may require applicants to reside within their jurisdiction. (c) Income – An applicant must meet an income standard established by the state agency or be determined to be automatically (adjunctively) income-eligible based on documentation of his or her eligibility, or certain family members’ eligibility, for the following federal programs: (1) Temporary Assistance for Needy Families, (2) Medicaid, or (3) Supplemental Nutrition Assistance Program (formerly the Food Stamp Program). State agencies may also determine an individual automatically income eligible, based on documentation of his or her eligibility for certain state-administered programs. (d) Nutritional Risk – A competent professional authority (e.g., physician, nutritionist, registered nurse, or other health professional) must determine that the applicant is at nutritional risk. While the broad guidelines for determining nutritional risk are set forth in WIC legislation and regulations, the specific allowable nutritional risk criteria are defined in WIC policy guidance, which is updated periodically. Each state agency may choose which allowable nutritional risk criteria will be used to determine eligibility. When an applicant meets all eligibility criteria, he or she is determined by WIC clinic staff to be eligible for program benefits. Certification periods are assigned to each participant based on categorical status for women, infants, and children (7 CFR Section 246.7(g)). A WIC local agency assigns each eligible person a priority classification according to the classification system described in 7 CFR Section 246.7(e)(4). A person’s priority assignment reflects the severity of his or her nutritional risk. If the local agency cannot immediately place the person on the program for lack of an available caseload slot, the person is placed on a waiting list. Caseload vacancies are filled from the waiting list in priority classification order. State agencies are expected to target program outreach and caseload management efforts toward persons at greatest nutritional risk (i.e., those in the highest priority classifications). Pregnant women are certified for the duration of their pregnancies and for up to six weeks postpartum. Breastfeeding women may be certified approximately every six months, up to one year postpartum, or until the woman ceases breastfeeding, whichever occurs first (7 CFR Section 246.7(g)(1)). Infants are certified at intervals of approximately six months, except that infants under six months of age may be certified for a period extending up to the child’s first birthday, provided the quality and accessibility of health care services are not diminished. Children are certified for six-month intervals ending with the last day of the month in which the child reaches the fifth birthday. State agencies also have the option to certify children for a period of one year if the state agency ensures that the child receives the required health and nutrition assessments (7 CFR Section 246.7(g)(1)). Non-breastfeeding women are certified for up to six months postpartum. All categories of participants may be certified up to the last day of the last month of the certification period (7 CFR Section 246.7(g)(1)). Condition: Advocate Aurora Health, Inc. screens applicants for eligibility by following the State of Wisconsin guidelines as provided through the State’s ROSIE system used to enter, track, and store information about applicants. Based on guidance contained in 7 CFR Section 246, states were encouraged to move to a paperless system. Specifically, federal guidance contained in 7 CFR 246.7 (i)(4) and (5)(i) outlines acceptable documentation to be included on certification forms as (1) “a description of the document(s) used to determine residency and identity or a copy of the document(s) used or the applicant’s written statement when no documentation exists,” and (2) “a description of the document(s) used to determine income eligibility or a copy of the document(s) in the file.” The State of Wisconsin has followed that guidance and does not require Advocate Aurora Health, Inc. to retain copies of an applicant’s proof of residence, income, etc., regarding eligibility. Therefore, we were not able to test internal controls over compliance or compliance over the eligibility compliance requirement through re-performance and we have issued a qualified opinion based on the scope limitations. Cause: Advocate Aurora Health, Inc. follows a paperless system as supported by the State of Wisconsin and the U.S. Department of Agriculture. The state does not require third-party supporting documentation of eligibility determinations to be retained. Effect or potential effect: Due to the online nature of the eligibility system, the program does not have documentation available for the audit team to test compliance with the eligibility requirement. A scope limitation qualified opinion was issued for ALN 10.557 as we were unable to obtain sufficient documentation supporting the compliance of Advocate Aurora Health, Inc. regarding eligibility. Questioned Costs: None. Context: Federal expenditures reported in the schedule of expenditures of federal awards for ALN 10.557 totaled $790,899 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: No further follow-up is required, as management of Advocate Aurora Health, Inc. is following the applicable guidance. Views of responsible officials and planned corrective actions: Management agrees with the finding.
Federal Agency: United States Department of Agriculture Food and Nutrition Service ALN: 16.575 Crime Victim Assistance (VOCA) Pass-Through Grantor: State of Illinois, Illinois Criminal Justice Information Authority and State of Wisconsin Department of Justice Pass-Through Award Number: 2021/2022-VO-A/VO-01-18139; 2023-VO-01-18830; 218690; 218692 Pass-Through Award Period: 10/1/2023 to 9/30/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.430(g)(1)(vi) of the Uniform Guidance states that the standards for documentation of personnel expense must “Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity”. Condition: Management did not have sufficiently designed internal controls to ensure that approved changes in employees’ effort certifications for salaries and wages were accurately recorded and charged to the grant. Cause: The Organization has internal controls in place to ensure employees’ effort certifications are approved. However, the Organization did not have internal controls to ensure that changes in employees’ certified effort were recorded and charged to the grant. Effect or potential effect: Unallowable payroll costs may be charged to the federal program. Questioned costs: $707 – Grant 218692 Context: We tested a sample of 25 payroll expenses, which totaled $28,826, for the period January 1, 2024 through December 31, 2024 and identified 3 transactions, which totaled $5,848. These three transactions had a change in effort during the period that was not reflected in the labor distribution causing the Advocate Aurora Health, Inc. to overcharge the grant by $707. The total VOCA expenditures reported on the Schedule are $2,098,275 for the year ended December 31, 2024. Payroll costs totaled $1,690,963, representing 84% of the total VOCA expenditures. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: Management should ensure that changes in effort made as a result of effort report certifications are reflected in the general ledger. Views of responsible officials: Advocate Aurora Management will develop and implement written procedures to ensure the timely communication of discrepancies identified during the effort certification process to the Grant Accounting team for appropriate review and adjustment.
Federal Agency: United States Department of Health and Human Services ALN: 93.788 Opioid STR Pass-Through Grantor: Illinois Department of Human Services Pass-Through Award Number: 43CCC03512 Award Period: 7/1/2023 to 6/30/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Per Exhibit B of the grant agreement dated June 12, 2024 between the State of Illinois, Department of Human Services and Advocate Health & Hospitals, patients who are residents of the State of Illinois and have indicated diagnosis of Opioid Use Disorder (OUD) are eligible to receive services. Condition: Management did not accurately document and retain evidence of the state of residency for participants in the federal program. Cause: Management did not have sufficiently designed internal controls to ensure that participants in the program were eligible to receive services through the program. Effect or potential effect: Ineligible participants may participate and receive benefits from the federal program. Questioned costs: None. Context: We tested a sample of 40 participants in the federal program for the period January 1, 2024 through December 31, 2024 and identified 8 participants where eligibility could not be redetermined or established. For seven of the participants, documentation was not retained to evidence the participants’ state of residence and for one participant they were listed as a resident of another state. The total Opioid STR expenditures reported on the Schedule are $1,105,537 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Organization should review its policies and procedures for determining and retaining evidence of participants’ eligibility and implement more robust internal controls to ensure proof of residency is confirmed and retained for participants in the federal program. Views of responsible officials: Management agrees with this finding and will develop a more robust process to verify participant eligibility. This process will include detailed steps and documentation, supported by a standardized eligibility checklist to guide staff in confirming and accurately recording participant eligibility.
Federal Agency: United States Department of Treasury ALN: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Period: 1/1/2023 to 6/30/2025 Pass-Through Grantor Pass-Through Award Number Illinois Department of Human Services FCSDX06443, FCSDX06444, FCSDX06445 Federal Agency: United States Department of Health and Human Services Assistance Listing Federal Program Name Pass-Through Grantor Pass-Through Award Number 93.889 National Bioterrorism Hospital Preparedness Program Illinois Health and Hospital Association 197137 Illinois Department of Public Health 47280007L; 47280009L; 57280007M; and 57280009M 93.958 Block Grants for Community Mental Health Services Illinois Department of Human Services 45CCB03507 and 45CDB04209 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.430(g)(1)(vi) of the Uniform Guidance states that the standards for documentation of personnel expense must “Support the distribution of the employee’s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity”. Condition: Management did not complete effort certifications for individuals working on multiple federal programs during the year. Cause: Management did not have sufficiently designed internal controls to ensure that effort certifications were completed for individuals working on multiple federal programs. Effect or potential effect: Unallowable payroll costs may be charged to the federal program. Questioned costs: None. Context: For Coronavirus State and Local Fiscal Recovery Funds, National Bioterrorism Hospital Preparedness Program, and Block Grants for Community Mental Health Service, Advocate Aurora Health did not have employees complete effort certifications when they were working on multiple federal programs. The total expenditures reported on the Schedule for Coronavirus State and Local Fiscal Recovery Funds, National Bioterrorism Hospital Preparedness Program, and Block Grants for Community Mental Health Service are $1,460,320, $952,593, and $926,262, respectively, for the year ended December 31, 2024. Payroll costs for Coronavirus State and Local Fiscal Recovery Fund, National Bioterrorism Hospital Preparedness Program, and Block Grants for Community Mental Health Service totaled $1,150,365, $94,265, and $752,385, respectively, representing 79%, 10%, and 81%, respectively of the total expenditures. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Organization should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the federal program. Views of responsible officials: Management agrees with the finding and will implement standardized procedures to ensure effort certifications are completed accurately and on time for all program staff.
Federal Agency: United States Department of Health and Human Services ALN: 93.889 National Bioterrorism Hospital Preparedness Program Pass-Through Grantor: Illinois Department of Public Health and Illinois Health and Hospital Association Pass-Through Award Number: 47280007L; 47280009L; 57280007M; 57280009M; and 197137 Award Period: 7/1/2023 to 6/30/2025 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.313(d)(1) and (2) states, “Regardless of whether equipment is acquired in part or its entirety under the Federal award, the recipient or subrecipient must manage equipment (including replacement equipment) utilizing procedures that meet the following requirements: (1) Property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and the disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. (2) A physical inventory of the property must be conducted, and the results must be reconciled with the property records at least once every two years.” Condition: The Organization did not retain property records documenting the appropriate criteria required by Section 200.313(d)(1) and (2), and did not conduct a physical inventory of property. Cause: The Organization did not have sufficiently designed internal controls to ensure that property records are retained in accordance with Section 200.313(d)(1) and (2), and to ensure that physical inventory procedures are conducted over property at least once every two years. Effect or potential effect: Federal equipment may not be maintained or disposed of in accordance with federal regulations. Questioned costs: None. Context: We tested a sample of 5 items from the equipment listing related to the federal program for the period January 1, 2024 through December 31, 2024. For all five items, there was no evidence that a physical inventory was performed in the last two years. For one item selected for testing the serial number listed on the listing did not match the serial number of the item selected. The total National Bioterrorism Hospital Preparedness Program expenditures reported on the Schedule are $952,593 for the year ended December 31, 2024. The net book value of all assets related to this federal program were $205,978. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Organization should implement more robust internal controls to ensure that accurate property records are maintained and physical inventory procedures over property are conducted at least once every two years. Views of responsible officials: Management agrees with the finding. Program and Fixed Asset Accounting teams will collaborate to ensure adherence to the established asset tracking and inventory management procedures. The joint effort will ensure that the subsidiary ledger is maintained, equipment acquired through federal grants is properly recorded, and physical inventories are conducted within the prescribed timelines.