Wisconsin Department of Health Services Planned Corrective Action:
Summer EBT was a brand-new program started in summer 2024 to provide food benefits during the
summer months to families with children who were determined eligible for free or reduced-price school
meals in the prior school year or dur...
Wisconsin Department of Health Services Planned Corrective Action:
Summer EBT was a brand-new program started in summer 2024 to provide food benefits during the
summer months to families with children who were determined eligible for free or reduced-price school
meals in the prior school year or during the summer. DHS provided benefits to over 450,000 children.
While DHS agrees with the cash management concerns cited by LAB under this program, we need to
clarify that the questioned costs do not represent inappropriate federal spending. While the federal funds
were received too early and remained in a bank account as of June 30, 2024, most of the funds were
paid out to eligible children during the following three months. A reconciliation of funds received to
funds spent for the children in this program was completed in early SFY 2024-25, with any unspent
balance returned to the federal government in September 2024.
DHS will work with DOA and our Summer EBT third-party vendor to improve the payment process,
ensuring compliance with federal requirements for future years.
Anticipated Completion Date: June 30, 2025Person responsible for corrective action:
Rebecca Mogensen, Section Chief
Managerial Accounting, Bureau of Fiscal Services, Division of Enterprise Services
rebeccaj.mogensen@dhs.wisconsin.gov Rebuttal from the Wisconsin Legislative Audit Bureau
In its corrective action plan on page 345, the Department of Health Services agreed with the cash
management concerns reported by the Bureau, but stated it did not consider the questioned costs to be
inappropriate federal spending. In addition, the Department of Health Services noted that it completed
a reconciliation of funds received to funds spent for children in this program and returned the unspent
balance to the federal government in September 2024. However, a questioned cost is defined by 2 CFR
s. 200.1 as an amount expended or received from a federal award, that in the auditor’s judgment:
is noncompliant or suspected noncompliant with federal statutes, regulations, or the
terms and conditions of the federal award;
lacked adequate documentation to support compliance; or
appeared unreasonable and did not reflect the actions a prudent person would take in
the circumstances.
As reported in the finding, United States Department of Agriculture guidance indicates that expenditures
or disbursements under the Summer Electronic Benefit Transfer Program for Children are incurred when
participants have used the issued benefits to purchase food. The amount questioned was the balance of
the federal funds drawn and not spent by participants as of June 30, 2024. This amount met the criteria of a
questioned cost due to noncompliance with federal regulations and a lack of adequate documentation to
support compliance. In addition, the return of $14.2 million to the federal government in September 2024
further indicates that the amounts drawn in June 2024 were not supported.