Wisconsin Department of Health Services Explanation Why Corrective Action Plan is Not Needed:
DHS disagrees with the unallowable costs identified in this finding. The $862,677 identified by LAB
was spent on vaccination distribution provided by a third-party provider, which is an allowable cost
accor...
Wisconsin Department of Health Services Explanation Why Corrective Action Plan is Not Needed:
DHS disagrees with the unallowable costs identified in this finding. The $862,677 identified by LAB
was spent on vaccination distribution provided by a third-party provider, which is an allowable cost
according to the memorandum of understanding (MOU) with DOA and the 2022 Treasury final rule.
DHS acknowledges that it incorrectly categorized these expenses in its federal reporting. However,
given the nature of these expenses, they would not have been unallowable, except for their
misclassification on the federal report.
Our position is supported by the fact that no accounting entries were needed to correct the eligible use
category for purposes of federal reporting, which has been completed. No further action is required.Contact Information:
Barry Kasten, Director
Bureau of Fiscal Services, Division of Enterprise Services
barry.kasten@dhs.wisconsin.govRebuttal from the Wisconsin Legislative Audit Bureau
In its corrective action plan on page 351, the Department of Health Services (DHS) indicated that it
disagrees with the unallowable costs identified in this finding and noted that the costs are allowable in
accordance with its memorandum of understanding with the Department of Administration and the
2022 Treasury final rule. As stated in the finding, DHS used $862,677 in expenditures under its COVID-19
vaccination distribution program as match for the Public Assistance grant. The 2022 Treasury final rule
and the U.S. Department of the Treasury (U.S. Treasury) frequently asked questions related to the
Coronavirus State Local and Fiscal Recovery Funds (CSLFRF) grant indicate that only funding under the
revenue loss eligible use category may be used to meet non-federal match for another federal program.
Therefore, using the expenditures for the COVID-19 vaccination distribution program as the non-federal
match for the Public Assistance grant is not allowable.
DHS indicated that “given the nature of these expenditures, they would not have been unallowable, except
for their misclassification on the federal report.” We note that the COVID-19 vaccination distribution
program has been reported under the public health eligible use category since its inception. Therefore, no
misclassification occurred on the federal report.
DHS noted that its position is supported by the fact that no accounting entries were needed to resolve the
eligible use category for the purpose of federal reporting. As we have stated, this issue relates to the
unallowable use of CSLFRF funding as non-federal match for another federal program. This is not a federal
reporting issue.
We note that subsequent to our questions regarding the use of these funds for non-federal match, the
State created a new U.S. Treasury project called COVID-19 Vaccination Non-Federal Match with a budget
of $862,677 and reported the project under the revenue loss eligible use category in its report filed for the
quarter ended December 31, 2024. Although the State chose to address the finding in this manner, it does
not change the fact that DHS was non-compliant with the matching requirements of the CSLFRF grant
when it used the funding from the COVID-19 vaccination distribution program as non-federal match for
another federal program.