Finding 1138531 (2024-001)

Assistance Listing, Federal Agency, and Program Name - ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Federal Award Identification Number and Year - E20243647-002 (2024) and E20243640-001 (2024) Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - Yes 2023-001 Criteria - Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligible participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l). Per 2 CFR 200.303(a), nonfederal entities must establish and maintain effective internal control over the federal award that provides resonable 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). Condition - During testing, it was noted that, although there was a process in place to review eligibility criteria received by program, there was no independent review or control to ensure eligibility was accurate for 11 months of the year. Questioned Costs - None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - From October 1, 2023 through September 30, 2024, all new participants requesting participation in the program are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility. This was the case for the first 11 months of the fiscal year. Given this was a prior year finding, the County implemented a new control with a secondary review that started in September 2024. Cause and Effect - There was no control in place to check eligibility after initial entry and recording of eligibility information within the program system. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants who are ineligible receiving benefits. Recommendation - We recommend that the County continue the internal control that was implemented in September 2024 to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information. Views of Responsible Officials and Corrective Action Plan - After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review. This was implemented in September of 2024.