FAC Explorer

Finding 1208489 (2025-007)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-04-22
Audit: 399474
Organization: Milwaukee Public Schools (WI)
Auditor: CLIFTONLARSONALLEN LLP

AI Summary

  • Core Issue: The District lacks effective internal controls to ensure required authorization (Form M-5) is obtained before billing Medicaid.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a) and Wisconsin DPI guidance on Medicaid billing for special education services.
  • Recommended Follow-Up: Implement controls to secure and retain Form M-5 prior to billing to prevent ineligible claims.

Finding Text

Federal Agency: United State of Department of Health and Human Services Federal Program Name: Medicaid Cluster Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2405WI5MAP-2024, 2505WI5MAP-2025 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Number(s): Not Available Award Period: July 1, 2024, through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: In accordance with 2 CFR 200.303(a), the District must establish and maintain effective internal control over the federal award that provides reasonable assurance that the District is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award In accordance with Wisconsin Department of Public Instruction guidance, each local education agency (LEA) that is a Medicaid-certified SBS provider is required to have a signed and dated DPI Consent to Bill Wisconsin Medicaid for Health-Related Special Education and Related Services (Form M-5) from the parent or guardian of a student with an IEP before claims can be submitted to BadgerCare Plus. Condition: A not statistically valid sample of 40 individuals with Medicaid billings filed during the fiscal year was selected. 3 of the 40 tested individuals did not have a DPI Consent to Bill Wisconsin Medicaid for Health-Related Special Education and Related Services (Form M-5) available for review. Questioned costs: $279.47 Context: The District was not able to produce documentation of the required Authorization to Bill (Form M-5) three (3) individuals selected for testing. The third-party billing service provided included that records had been sighted previously for these individual, but were not available for review during testing. Cause: Internal controls in place at the District are not designed and implemented to ensure the required authorization to bill Medicare is obtained prior to initial billing and retained for future review. Effect: The District may bill for services that are not eligible for reimbursement under the state of Wisconsin administered Medicaid program. Repeat Finding: No. Recommendation: We recommend the District design and implement controls to ensure required authorization to bill Medicare (Form M-5) is obtained prior to initial billing. We also recommend the District design and implement controls to ensure a copy of this form is retained in accordance with federal and state requirements and is available for future required reviews. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Medicaid Cluster – Assistance Listing No. 93.778 Recommendation: The District should design and implement controls to ensure required authorization to bill Medicare (Form M-5) is obtained prior to initial billing. We also recommend the District design and implement controls to ensure a copy of this form is retained in accordance with Federal and State requirements and is available for future required reviews. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will strengthen internal controls to ensure all required authorizations are obtained and properly maintained prior to billing. MPS will accomplish this through the execution of the following: • Implementing a pre-billing verification process to confirm a completed Form M-5 is on file before any initial Medicaid billing occurs, • Establishing a standardized documentation procedure to ensure all Forms M-5 are securely retained and readily accessible for review, • Creating a centralized tracking system to monitor the status of required authorizations for all eligible students, • Conducting periodic internal reviews to ensure compliance with authorization and documentation requirements, • Providing training to relevant staff on Medicaid billing requirements and record retention expectations. Name(s) of the contact person(s) responsible for corrective action: Budget Director, Accounting Director (Deputy CFO), Financial Reporting Manager Planned completion date for corrective action plan: Implementation of the new process is currently underway and will be remediated in the coming months of FY26 and into FY27.

Categories

Cash Management Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1208470 2025-005
    Material Weakness Repeat
  • 1208471 2025-005
    Material Weakness Repeat
  • 1208472 2025-005
    Material Weakness Repeat
  • 1208473 2025-005
    Material Weakness Repeat
  • 1208474 2025-005
    Material Weakness Repeat
  • 1208475 2025-005
    Material Weakness Repeat
  • 1208476 2025-005
    Material Weakness Repeat
  • 1208477 2025-006
    Material Weakness Repeat
  • 1208478 2025-006
    Material Weakness Repeat
  • 1208479 2025-006
    Material Weakness Repeat
  • 1208480 2025-006
    Material Weakness Repeat
  • 1208481 2025-006
    Material Weakness Repeat
  • 1208482 2025-006
    Material Weakness Repeat
  • 1208483 2025-006
    Material Weakness Repeat
  • 1208484 2025-006
    Material Weakness Repeat
  • 1208485 2025-006
    Material Weakness Repeat
  • 1208486 2025-006
    Material Weakness Repeat
  • 1208487 2025-006
    Material Weakness Repeat
  • 1208488 2025-006
    Material Weakness Repeat
  • 1208490 2025-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
10.553 SCHOOL BREAKFAST PROGRAM $13.89M
93.778 GRANTS TO STATES FOR MEDICAID $8.50M
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $5.40M
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $5.16M
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $4.37M
10.555 NATIONAL SCHOOL LUNCH PROGRAM $3.69M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.39M
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $1.70M
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $1.66M
10.558 CHILD AND ADULT CARE FOOD PROGRAM $1.40M
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $1.36M
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $1.32M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.32M
84.299 INDIAN EDUCATION -- SPECIAL PROGRAMS FOR INDIAN CHILDREN $667,710
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $631,358
15.662 GREAT LAKES RESTORATION $549,085
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $400,635
84.374 TEACHER AND SCHOOL LEADER INCENTIVE GRANTS (FORMERLY THE TEACHER INCENTIVE FUND) $384,921
93.327 DEMONSTRATION GRANTS FOR DOMESTIC VICTIMS OF HUMAN TRAFFICKING $248,663
66.509 SCIENCE TO ACHIEVE RESULTS (STAR) RESEARCH PROGRAM $203,342
84.051 CAREER AND TECHNICAL EDUCATION -- NATIONAL PROGRAMS $193,950
20.205 HIGHWAY PLANNING AND CONSTRUCTION $162,331
66.609 PROTECTION OF CHILDREN FROM ENVIRONMENTAL HEALTH RISKS $137,650
93.566 REFUGEE AND ENTRANT ASSISTANCE STATE/REPLACEMENT DESIGNEE ADMINISTERED PROGRAMS $132,713
84.411 EDUCATION INNOVATION AND RESEARCH (FORMERLY INVESTING IN INNOVATION (I3) FUND) $128,860
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $106,026
16.839 STOP SCHOOL VIOLENCE $101,162
84.206 JAVITS GIFTED AND TALENTED STUDENTS EDUCATION $96,757
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $93,508
15.916 OUTDOOR RECREATION ACQUISITION, DEVELOPMENT AND PLANNING $88,223
10.935 URBAN AGRICULTURE AND INNOVATIVE PRODUCTION GRANTS PROGRAM (UAIP) $63,807
84.027 SPECIAL EDUCATION GRANTS TO STATES $62,519
84.060 INDIAN EDUCATION FORMULA GRANTS $55,058
11.419 COASTAL ZONE MANAGEMENT ADMINISTRATION AWARDS $50,000
84.041 IMPACT AID $49,930
10.675 URBAN AND COMMUNITY FORESTRY PROGRAM $40,000
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $20,753
84.425 EDUCATION STABILIZATION FUND $7,438
10.902 SOIL AND WATER CONSERVATION $4,503