Finding 1201591 (2025-001)

Material Weakness Repeat Finding
Requirement
H
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 396143
Organization: City of Cincinnati (OH)

AI Summary

  • Core Issue: WIC expenditures are charged to the oldest open grant, leading to potential misallocation of costs.
  • Impacted Requirements: Noncompliance with 2 CFR 200.309, which mandates tracking costs to specific grant periods.
  • Recommended Follow-Up: Implement procedures to track WIC expenditures by individual grant periods to prevent errors and fraud.

Finding Text

Period of Performance – Significant Deficiency and Noncompliance ALN 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Condition: WIC expenditures are charged to the oldest open WIC grant regardless of when specific costs are incurred. WIC expenditures are comingled and are not tracked separately by each grant. Criteria: In accordance with 2 CFR 200.309, costs charged to a federal award must be incurred during the approved period of performance and supported by adequate records to demonstrate allocability to the specific grant period. Effect: The lack of grant-level tracking between grant periods increases the risk that costs could be charged to an incorrect grant period, increasing the risk of fraud, error, or omission in grant administration. Questioned Costs: Utilizing cutoff testing between specific ending grant periods, our testing identified $166,317 in questioned costs. Cause: The City lacks procedures and system controls to track WIC expenditures by individual grant award and period of performance. Recommendation: We recommend the City implement procedures to ensure WIC expenditures are tracked and supported by individual grant period. This may include maintaining details for each individual grants or enhancing existing processes to ensure expenditures are charged to the appropriate period of performance. Views of Responsible Officials: See the City’s Corrective Action Plan.

Corrective Action Plan

Planned Corrective Action: The City acknowledges the finding. Based on the recommendation, the City plans to do the following: • Establish separate program/project accounts within the financial system for each WIC grant award to ensure expenditures are recorded and tracked individually by grant period. • Develop and implement written procedures requiring that all expenditures be reviewed and recorded based on the date incurred relative to the grant’s period of performance. • Perform monthly reconciliations of WIC expenditures by grant to verify that costs are accurately recorded and aligned with the appropriate funding period. • Implement period-end cutoff procedures to ensure expenditures near grant end dates are reviewed and properly assigned to the correct grant period. CHD Fiscal will begin implementing the plan by creating the program codes and will meet with WIC to establish roles for the written procedures. Anticipated Completion Date: 06/30/2026 Responsible Contact Person: Mark Menkhaus, Division Manager

Categories

Period of Performance Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
20.205 HIGHWAY PLANNING AND CONSTRUCTION $12.24M
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $10.18M
93.224 HEALTH CENTER PROGRAM $6.47M
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $5.32M
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $3.41M
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $2.42M
14.241 HOUSING OPPORTUNITIES FOR PERSONS WITH AIDS $1.42M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $1.41M
93.217 FAMILY PLANNING SERVICES $1.22M
14.905 LEAD HAZARD REDUCTION DEMONSTRATION GRANT PROGRAM $1.03M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $829,936
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $731,796
16.922 EQUITABLE SHARING PROGRAM $547,564
97.056 PORT SECURITY GRANT PROGRAM $434,314
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $418,208
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $380,958
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $365,426
20.507 FEDERAL TRANSIT FORMULA GRANTS $355,375
84.425 EDUCATION STABILIZATION FUND $301,744
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $290,038
97.067 HOMELAND SECURITY GRANT PROGRAM $281,911
93.074 HOSPITAL PREPAREDNESS PROGRAM (HPP) AND PUBLIC HEALTH EMERGENCY PREPAREDNESS (PHEP) ALIGNED COOPERATIVE AGREEMENTS $230,715
20.939 SAFE STREETS AND ROADS FOR ALL $202,466
10.935 URBAN AGRICULTURE AND INNOVATIVE PRODUCTION GRANTS PROGRAM (UAIP) $192,604
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $184,881
93.305 PPHF 2018: OFFICE OF SMOKING AND HEALTH-NATIONAL STATE-BASED TOBACCO CONTROL PROGRAMS-FINANCED IN PART BY 2018 PREVENTION AND PUBLIC HEALTH FUNDS (PPHF) $156,254
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $111,946
97.044 ASSISTANCE TO FIREFIGHTERS GRANT $92,438
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $75,511
16.609 PROJECT SAFE NEIGHBORHOODS $53,126
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $52,410
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $42,631
66.509 SCIENCE TO ACHIEVE RESULTS (STAR) RESEARCH PROGRAM $31,912
16.015 MISSING ALZHEIMER'S DISEASE PATIENT ASSISTANCE PROGRAM $23,184
16.590 GRANTS TO ENCOURAGE ARREST POLICIES AND ENFORCEMENT OF PROTECTION ORDERS PROGRAM $12,839
16.575 CRIME VICTIM ASSISTANCE $12,101