Federal Agency: United States Department of Agriculture Food and Nutrition Service ALN: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Pass-Through Grantor: State of Wisconsin Department of Health Services – Wisconsin Department of Health and Family Services Pass-Through Award Number: 154710 Pass-Through Award Period: 1/1/2024 to 12/31/2024 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the following eligibility criteria (7 CFR Sections 246.7(c), (d), (e), (g), and (l)): (a) Categorical – Eligibility is restricted to pregnant, postpartum and breastfeeding women; infants; and children up to their fifth birthday (7 CFR Sections 246.2 (definition of each category) and 246.7(c)). (b) Identity and Residency – Except in limited circumstances, WIC applicants must be physically present for eligibility screenings and must provide proof of identity. An applicant must also meet the state agency residency requirement. Except in the case of Indian state agencies, the applicant must reside in the jurisdiction of the state. Indian state agencies may require applicants to reside within their jurisdiction. (c) Income – An applicant must meet an income standard established by the state agency or be determined to be automatically (adjunctively) income-eligible based on documentation of his or her eligibility, or certain family members’ eligibility, for the following federal programs: (1) Temporary Assistance for Needy Families, (2) Medicaid, or (3) Supplemental Nutrition Assistance Program (formerly the Food Stamp Program). State agencies may also determine an individual automatically income eligible, based on documentation of his or her eligibility for certain state-administered programs. (d) Nutritional Risk – A competent professional authority (e.g., physician, nutritionist, registered nurse, or other health professional) must determine that the applicant is at nutritional risk. While the broad guidelines for determining nutritional risk are set forth in WIC legislation and regulations, the specific allowable nutritional risk criteria are defined in WIC policy guidance, which is updated periodically. Each state agency may choose which allowable nutritional risk criteria will be used to determine eligibility. When an applicant meets all eligibility criteria, he or she is determined by WIC clinic staff to be eligible for program benefits. Certification periods are assigned to each participant based on categorical status for women, infants, and children (7 CFR Section 246.7(g)). A WIC local agency assigns each eligible person a priority classification according to the classification system described in 7 CFR Section 246.7(e)(4). A person’s priority assignment reflects the severity of his or her nutritional risk. If the local agency cannot immediately place the person on the program for lack of an available caseload slot, the person is placed on a waiting list. Caseload vacancies are filled from the waiting list in priority classification order. State agencies are expected to target program outreach and caseload management efforts toward persons at greatest nutritional risk (i.e., those in the highest priority classifications). Pregnant women are certified for the duration of their pregnancies and for up to six weeks postpartum. Breastfeeding women may be certified approximately every six months, up to one year postpartum, or until the woman ceases breastfeeding, whichever occurs first (7 CFR Section 246.7(g)(1)). Infants are certified at intervals of approximately six months, except that infants under six months of age may be certified for a period extending up to the child’s first birthday, provided the quality and accessibility of health care services are not diminished. Children are certified for six-month intervals ending with the last day of the month in which the child reaches the fifth birthday. State agencies also have the option to certify children for a period of one year if the state agency ensures that the child receives the required health and nutrition assessments (7 CFR Section 246.7(g)(1)). Non-breastfeeding women are certified for up to six months postpartum. All categories of participants may be certified up to the last day of the last month of the certification period (7 CFR Section 246.7(g)(1)). Condition: Advocate Aurora Health, Inc. screens applicants for eligibility by following the State of Wisconsin guidelines as provided through the State’s ROSIE system used to enter, track, and store information about applicants. Based on guidance contained in 7 CFR Section 246, states were encouraged to move to a paperless system. Specifically, federal guidance contained in 7 CFR 246.7 (i)(4) and (5)(i) outlines acceptable documentation to be included on certification forms as (1) “a description of the document(s) used to determine residency and identity or a copy of the document(s) used or the applicant’s written statement when no documentation exists,” and (2) “a description of the document(s) used to determine income eligibility or a copy of the document(s) in the file.” The State of Wisconsin has followed that guidance and does not require Advocate Aurora Health, Inc. to retain copies of an applicant’s proof of residence, income, etc., regarding eligibility. Therefore, we were not able to test internal controls over compliance or compliance over the eligibility compliance requirement through re-performance and we have issued a qualified opinion based on the scope limitations. Cause: Advocate Aurora Health, Inc. follows a paperless system as supported by the State of Wisconsin and the U.S. Department of Agriculture. The state does not require third-party supporting documentation of eligibility determinations to be retained. Effect or potential effect: Due to the online nature of the eligibility system, the program does not have documentation available for the audit team to test compliance with the eligibility requirement. A scope limitation qualified opinion was issued for ALN 10.557 as we were unable to obtain sufficient documentation supporting the compliance of Advocate Aurora Health, Inc. regarding eligibility. Questioned Costs: None. Context: Federal expenditures reported in the schedule of expenditures of federal awards for ALN 10.557 totaled $790,899 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: No further follow-up is required, as management of Advocate Aurora Health, Inc. is following the applicable guidance. Views of responsible officials and planned corrective actions: Management agrees with the finding.