Finding 1138521 (2024-101)

Material Weakness
Requirement
E
Questioned Costs
$1
Year
2024
Accepted
2025-05-30
Audit: 357695
Organization: Cochise County (AZ)

AI Summary

  • Core Issue: The County’s Health and Social Services Department failed to obtain signed rights and obligations forms from WIC participants, violating federal and state eligibility requirements.
  • Impacted Requirements: This oversight increases the risk of inaccurate eligibility determinations and potential misuse of benefits, as participants may not understand program rules.
  • Recommended Follow-Up: Implement training for staff on eligibility processes, ensure compliance with signing requirements, and conduct regular monitoring of clinic sites to uphold program integrity.

Finding Text

Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award numbers and years: CTR040363, October 1, 2018 through September 30, 2023; CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Department of Agriculture Pass-through grantor: Arizona Department of Health Services Compliance requirement: Eligibility Questioned costs: Unknown1 Condition—Contrary to federal regulations and State policies, the County’s Health and Social Services Department (Department) issued program benefits without requiring each program participant to complete and sign a rights and obligations form during the eligibility certification process agreeing to provide current and truthful information, abide by program rules, and not share WIC benefits cards or other benefits. Specifically, for 15 of 62 participants tested, the Department did not require the participants to complete and sign a rights and obligations form for 6 participants’ initial certifications and 9 participants’ recertifications for ongoing benefits. Effect—The Department’s not requiring program participants to acknowledge their rights and obligations increases the risk of participants providing inaccurate information required for eligibility determinations, such as erroneous residency and income data that could allow program participants to receive benefits they are not eligible to receive.1 Further, there is an increased risk of misuse of program benefits received as the participants may not be aware of the program’s rules and could allow others to use their WIC benefits cards or sell, trade, or give away benefits received, such as food, formula, or breast pumps. Cause—Department management reported that State policies were not always followed because the program is administered at small clinic sites throughout the County, and Department staff who are responsible for ensuring each program participant complete and sign a rights and obligations form were busy and forgot to have each program participant do so. Further, the Department did not perform periodic monitoring to ensure Department clinic site staff had required participants to sign the rights and obligations form prior to issuing benefits and that the forms were maintained in its eligibility system. Criteria—Federal regulation and State policies require participants to sign a rights and obligations statement as part of the eligibility certification process (7 CFR 246.7[i][10]).2 Specifically, State eligibility certification policies require the Department’s staff who are responsible for the eligibility certification process to inform participants of their rights and obligations prior to issuing benefits during the participant’s initial certification and recertifications for ongoing benefits. Also, the participants must complete and sign the form acknowledging their rights and obligations, including: • Providing the most current and truthful information that WIC staff may verify. • Following the rules of the WIC program to avoid being prosecuted, disqualified, and/or asked to repay the program. • Allowing only the approved authorized recipient or proxy to use the WIC benefits card and reporting lost or stolen WIC benefits cards.1 • Being honest and not selling, trading, or giving away WIC benefits cards, food, formula, or breast pumps, and acknowledging that doing so will disqualify the recipient from benefits. Further, federal guidelines require establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department— 1. Follow the State’s eligibility certification policies that require program participants to complete and sign a rights and obligations form prior to the Department issuing benefits during initial certifications and recertifications for ongoing benefits. 2. Train Department staff who are responsible for the eligibility certification process regarding the following requirements: a. Participants must be informed of their rights and obligations prior to issuing benefits during the participant’s initial certification and recertifications for ongoing benefits. b. Participants must sign the rights and obligations form during the eligibility certification process agreeing to provide current and truthful information, abide by program rules, and not share WIC benefits cards or other benefits. c. Department staff must maintain the forms in its eligibility system. 3. Perform periodic monitoring at its clinic sites to ensure Department staff who are responsible for the eligibility certification process are performing all steps. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 WIC recipients receive WIC benefits cards to use at designated vendors, such as a grocery store, that are preloaded with eligible food packages. A food package contains items by description and provides only specific quantities for fruits and vegetables. For example, 2 dozen eggs, 32 ounces of yogurt, 1 pound of cheese, etc. The recipient can purchase only the eligible items and specific quantities outlined in their designated food package. Unused benefits expire at the end of the month. For the errors identified, auditors were unable to determine the potential questioned cost as there is not a specific amount designated for each food package awarded to the recipients. The vendors who supplied food to the recipient bill the Arizona Department of Health Services for the benefits provided. 2 Arizona Department of Health Services. (2024). Arizona WIC Program Policy and Procedure Manual Chapter 2, Section H. Retrieved 4/30/2025 from https://www.azdhs.gov/documents/prevention/azwic/manuals/policy/chapter-02-certification.pdf?v=20240221

Categories

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility Reporting

Other Findings in this Audit

  • 562079 2024-101
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.391 Covid-19 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.05M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $656,472
93.268 Covid-19 Immunization Cooperative Agreements $469,514
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $457,322
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $456,889
97.067 Homeland Security Grant Program $371,481
20.106 Airport Improvement Program, Covid-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs $371,000
10.665 Schools and Roads - Grants to States $350,788
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $338,348
84.425 Covid-19 Education Stabilization Fund $320,177
93.069 Public Health Emergency Preparedness $299,817
14.871 Section 8 Housing Choice Vouchers $279,846
14.241 Housing Opportunities for Persons with Aids $265,520
95.001 High Intensity Drug Trafficking Areas Program $258,677
16.710 Public Safety Partnership and Community Policing Grants $236,137
97.042 Emergency Management Performance Grants $188,113
93.788 Opioid Str $169,599
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $156,030
12.017 Readiness and Environmental Protection Integration (repi) Program $155,155
16.738 Edward Byrne Memorial Justice Assistance Grant Program $112,386
93.110 Maternal and Child Health Federal Consolidated Programs $107,141
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $101,791
93.136 Injury Prevention and Control Research and State and Community Based Programs $100,076
93.994 Maternal and Child Health Services Block Grant to the States $97,432
16.576 Covid-19 Crime Victim Compensation $94,692
14.896 Family Self-Sufficiency Program $84,175
20.205 Highway Planning and Construction $82,865
93.658 Foster Care Title IV-E $78,899
20.600 State and Community Highway Safety $69,342
21.032 Covid-19 Local Assistance and Tribal Consistency Fund $66,905
93.268 Immunization Cooperative Agreements $52,483
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $43,744
93.991 Preventive Health and Health Services Block Grant $29,722
93.597 Grants to States for Access and Visitation Programs $26,991
20.616 National Priority Safety Programs $25,955
16.575 Crime Victim Assistance $20,460
93.563 Child Support Services $15,789
10.U01 National Forest System - Law Enforcement $11,072
84.027 Special Education Grants to States $9,729
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $7,000
90.404 Hava Election Security Grants $6,364
97.U03 Homeland Security Unknown $6,278
93.575 Covid-19 Child Care and Development Block Grant $4,181
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $4,096
93.103 Food and Drug Administration Research $3,558
12.U02 Forest Product Sales $546