Finding 1157076 (2024-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-09-30
Audit: 369390
Organization: Unity Health Care, Inc. (MD)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The Corporation failed to properly review eligibility assessments for WIC program benefits, leading to potential ineligibility of beneficiaries.
  • Impacted Requirements: Key eligibility criteria related to Category, Identity and Residency, Income, and Nutritional Risk were not consistently followed, violating 7 CFR sections 246.7.
  • Recommended Follow-Up: Implement formal internal controls and ensure proper documentation to maintain segregation of duties in the eligibility assessment process.

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 support that eligibility assessments performed were reviewed. For 2 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. Cause: The staff did not consistently follow formal policies and procedures over eligibility. Effect or Potential Effect: Lack of strict adherence to documentation requirements may have resulted in the Corporation providing benefits to ineligible beneficiaries. Questioned costs: None Context: We tested a sample of 40 participants determined to be eligible 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: This is a repeat finding from prior year. This was reported as finding 2023-008 in the 2023 report. 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 staff turnover, the Corporation did not consistently enforce segregation of duties between the individual responsible for determining income eligibility and the one completing the medical risk assessment.

Corrective Action Plan

Management Response #2024-004: Due to staff turnover, the Corporation did not consistently enforce segregation of duties between the individual responsible for determining income eligibility and the one completing the medical risk assessment. Corrective Action Plan: All eligibility verification data, including screenshots and signed Rights and Obligations statements, will be stored in a centralized, secure shared drive maintained and managed by the WIC Director to ensure it is protected with limited access and password protection. The drive will be organized using a de-identified naming convention to ensure privacy while maintaining ease of access for authorized staff. To maintain a robust system of checks and balances, tasks related to eligibility verification and documentation will be divided among different team members. This separation will prevent any one individual from having full control over the process, reducing the risk of oversight or potential errors. The WIC Department’s policy and procedure manuals will be revised and updated to include the new eligibility verification process. To ensure adherence to the new protocols, periodic audits and review sessions will be conducted by the WIC Director or designated compliance staff to verify that documentation is being properly maintained and that all procedures are followed. Staff will be required to undergo refresher training sessions as needed to reinforce the updated protocols and best practices. Management expects to be completed by December 31, 2026. Responsible Party: Tracy Harrison, COO

Categories

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 1157059 2024-001
    Material Weakness Repeat
  • 1157060 2024-002
    Material Weakness Repeat
  • 1157061 2024-003
    Material Weakness Repeat
  • 1157062 2024-001
    Material Weakness Repeat
  • 1157063 2024-002
    Material Weakness Repeat
  • 1157064 2024-003
    Material Weakness Repeat
  • 1157065 2024-001
    Material Weakness Repeat
  • 1157066 2024-002
    Material Weakness Repeat
  • 1157067 2024-005
    Material Weakness Repeat
  • 1157068 2024-001
    Material Weakness Repeat
  • 1157069 2024-002
    Material Weakness Repeat
  • 1157070 2024-005
    Material Weakness Repeat
  • 1157071 2024-001
    Material Weakness Repeat
  • 1157072 2024-002
    Material Weakness Repeat
  • 1157073 2024-005
    Material Weakness Repeat
  • 1157074 2024-001
    Material Weakness Repeat
  • 1157075 2024-002
    Material Weakness Repeat
  • 1157077 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $7.41M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $5.37M
93.788 Opioid Str $1.47M
93.914 Hiv Emergency Relief Project Grants $1.24M
93.217 Family Planning Services $1.11M
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $451,849
93.917 Hiv Care Formula Grants $395,938
93.247 Advanced Nursing Education Workforce Grant Program $343,619
93.855 Allergy and Infectious Diseases Research $330,035
93.994 Maternal and Child Health Services Block Grant to the States $287,682
93.837 Cardiovascular Diseases Research $259,513
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $118,679
93.884 Primary Care Training and Enhancement $99,465
93.527 Grants for New and Expanded Services Under the Health Center Program $72,274
93.526 Grants for Capital Development in Health Centers $62,276
93.426 The National Cardiovascular Health Program $57,990
93.107 Area Health Education Centers $53,711
93.242 Mental Health Research Grants $1,519