Finding Text
Criteria: Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the eligibility criteria defined at 7 CFR sections 246.7(c), (d), (e), (g), and (l) related to Category, Identity and Residency, Income, and Nutritional Risk.
Condition: During our testing of eligibility, the Corporation was unable to provide eligibility data for the period January 1, 2022 through March 31, 2022 and therefore we were unable to assess eligibility compliance requirements during that period. In addition, the Corporation was unable to provide support that eligibility assessments performed were reviewed. Below is a summary of our findings:
• For 6 of the 40 samples, proper segregation of duties was not maintained as the staff person who determined income eligibility was the same staff person who completed the medical risk assessment.
• For 23 of the 40 samples, the Corporation was unable to provide support to verify the applicant signed the Rights and Obligations statement.
• For 3 out of the 40 samples, the Corporation was unable to provide documentation that the applicant met the residency eligibility requirement.
• For 27 out of the 40 samples, the Corporation was unable to provide documentation that the applicant met the income eligibility requirement.
• For 14 out of the 40 samples, the Corporation was unable to provide documentation that the applicant met the category eligibility requirement.
• For 9 out of the 40 samples, the Corporation was unable to provide documentation that the applicant met the nutritional risk eligibility requirement.
• For 1 out of the 40 samples, it was noted the certified applicant did not provide documentation to support the required residency requirement. Participants who do not provide residency documentation are required to provide residency documentation within 30 days. The Corporation was unable to provide evidence the participant provided residency support within 30 days.
• For all 40 samples, the Corporation was unable to provide support that the eligibility assessments performed were reviewed.
Cause: The Corporation did not have formal policies and procedures over subrecipient monitoring.
Effect or Potential Effect: Lack of strict adherence to documentation requirements may have resulted in the Organization providing benefits to ineligible beneficiaries.
Questioned costs: None
Context: We tested a sample of 40 participants determined to be eligible and noted the Corporation was not able to produce sufficient and appropriate evidence that eligibility assessments performed were reviewed, and found exceptions as noted in the condition. This is a condition identified per review of the Corporation’s compliance with specified requirements using a statistically valid sample.
Repeat finding: No
Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating to assessing eligibility of participants.
View of Responsible Officials: Due to a change in reporting systems used to assess eligibility, the Corporation did not have access to the eligibility data for the period January 1, 2022 through March 31, 2022. Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation did not maintain sufficient or appropriate evidence that eligibility assessments performed were reviewed.