Finding 1235783 (2025-005)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-09-21
Audit: 411436
Organization: Manitowoc County (WI)

AI Summary

  • Core Issue: The County submitted administrative costs for reimbursement that were already recouped from Medicaid, leading to a material weakness in internal controls.
  • Impacted Requirements: Compliance with Allowable Costs/Cost Principles under CFR 200.403 was violated, as costs reported were not eligible for reimbursement.
  • Recommended Follow-Up: The Department should create a uniform payroll allocation process and redesign its accounting structure to prevent double reporting of costs.

Finding Text

Finding No. 2025-005 Federal Agency: U.S Department of Health Services Federal Program Name: Medicaid Cluster Assistance Listing Number: 93.778 Pass Through Entity: Wisconsin Department of Health Services Federal Award Notification Number and Year: All – 2025 Award Period: January 1, 2025 – December 31, 2025 Compliance Requirement Affected: Reporting Type of Finding: Material Weakness in Internal Control Over Compliance Criteria or Specific Requirement: Allowable Costs/Cost Principles - CFR 200.403 Factors Affecting Allowability Of Costs requires that reported costs not be included as a cost of any other federally financed program. Condition: During testing of the Wisconsin Children’s Long-Term Support Medicaid Waiver program, (CLTS), a material difference was noted between the total of the monthly amounts submitted as administrative costs and total amount submitted on the annual grant reconciliation report. The program expectation is that the total of the monthly amounts should be comparable to the amount submitted on the annual reconciliation. Questioned Costs: None Context: The Wisconsin Department of Health Services (WI DHS) CLTS program allows counties to claim a self-calculated administrative cost each month for reimbursement, with the final payment early the following year. A separate annual report that requires a higher level of detail is due in early April of the following year, including each employee's payroll costs, hours worked both in and out of the program, paid time off and details of any additional administrative costs reported. WI DHS reconciles the submitted costs on the annual report with the amounts already billed to the State CLTS Medicaid program and considers any unreimbursed amounts to be administrative costs. Those costs are compared to the amounts the County reported and has already been reimbursed. WI DHS either pays or takes back the difference. Cause: The County submitted $458,639 in monthly administrative costs for reimbursement which they had already recouped from the Medicaid billing program; they received payments of $236,429 from those submitted costs based on contract limitations. The grand total submitted for 2025 administrative reimbursement was $571,458; the County was ultimately entitled to $112,820 after the annual reconciliation report was reviewed and approved by WI DHS. The County received reimbursements totaling $216,433 through November 2025, with an additional $132,816 in reimbursements received through May 2026. WI DHS recouped the $236,429 overpayment in June 2026. Effect: The County submitted administrative costs for reimbursement under WI DHS CLTS program which were previously recouped from the Medicaid billing program. As a result, the County had to pay back $236,429 to WI DHS for this duplicate reporting. Recommendation: The Human Services Department (the Department) should develop a uniform payroll allocation process that will allocate all employee costs to each program based on actual hours worked, including fiscal and administrative employees. They should also implement a uniform account structure that includes the objects necessary to track program costs, so they can be used to accurately calculate and report costs in accordance with all program requirements. In addition, the Department should redesign its accounting, reporting and reconciliation structure to include all programs and prevents double reporting from happening. Views of Responsible Officials: There is no disagreement with the finding.

Corrective Action Plan

Recommendation: We recommend the Human Services Department develop a uniform payroll allocation process that will allocate all employee costs to each program based on actual hours worked, including fiscal and administrative employees. They should also implement a uniform account structure that includes the objects necessary to track program costs, so they can be used to accurately calculate and report costs in accordance with all program requirements. In addition, the Department should redesign its accounting, reporting and reconciliation structure to include all programs and prevents double reporting from happening. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action planned in response to finding: Management has begun a review of the Human Services Department payroll allocation process. Name(s) of the contact person(s) responsible for corrective action: Melissa Diener, Assistant Finance Director Planned completion date for corrective action plan: The County has begun evaluating procedures and will implement as soon as possible.

Categories

Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1235746 2025-004
    Material Weakness Repeat
  • 1235747 2025-004
    Material Weakness Repeat
  • 1235748 2025-004
    Material Weakness Repeat
  • 1235749 2025-004
    Material Weakness Repeat
  • 1235750 2025-004
    Material Weakness Repeat
  • 1235751 2025-004
    Material Weakness Repeat
  • 1235752 2025-004
    Material Weakness Repeat
  • 1235753 2025-004
    Material Weakness Repeat
  • 1235754 2025-004
    Material Weakness Repeat
  • 1235755 2025-004
    Material Weakness Repeat
  • 1235756 2025-004
    Material Weakness Repeat
  • 1235757 2025-004
    Material Weakness Repeat
  • 1235758 2025-004
    Material Weakness Repeat
  • 1235759 2025-004
    Material Weakness Repeat
  • 1235760 2025-004
    Material Weakness Repeat
  • 1235761 2025-004
    Material Weakness Repeat
  • 1235762 2025-004
    Material Weakness Repeat
  • 1235763 2025-004
    Material Weakness Repeat
  • 1235764 2025-004
    Material Weakness Repeat
  • 1235765 2025-004
    Material Weakness Repeat
  • 1235766 2025-004
    Material Weakness Repeat
  • 1235767 2025-004
    Material Weakness Repeat
  • 1235768 2025-004
    Material Weakness Repeat
  • 1235769 2025-004
    Material Weakness Repeat
  • 1235770 2025-004
    Material Weakness Repeat
  • 1235771 2025-004
    Material Weakness Repeat
  • 1235772 2025-004
    Material Weakness Repeat
  • 1235773 2025-004
    Material Weakness Repeat
  • 1235774 2025-004
    Material Weakness Repeat
  • 1235775 2025-004
    Material Weakness Repeat
  • 1235776 2025-004
    Material Weakness Repeat
  • 1235777 2025-005
    Material Weakness Repeat
  • 1235778 2025-005
    Material Weakness Repeat
  • 1235779 2025-005
    Material Weakness Repeat
  • 1235780 2025-005
    Material Weakness Repeat
  • 1235781 2025-005
    Material Weakness Repeat
  • 1235782 2025-005
    Material Weakness Repeat
  • 1235784 2025-007
    Material Weakness Repeat
  • 1235785 2025-007
    Material Weakness Repeat
  • 1235786 2025-007
    Material Weakness Repeat
  • 1235787 2025-007
    Material Weakness Repeat
  • 1235788 2025-007
    Material Weakness Repeat
  • 1235789 2025-007
    Material Weakness Repeat
  • 1235790 2025-007
    Material Weakness Repeat
  • 1235791 2025-007
    Material Weakness Repeat
  • 1235792 2025-007
    Material Weakness Repeat
  • 1235793 2025-007
    Material Weakness Repeat
  • 1235794 2025-007
    Material Weakness Repeat
  • 1235795 2025-007
    Material Weakness Repeat
  • 1235796 2025-007
    Material Weakness Repeat
  • 1235797 2025-007
    Material Weakness Repeat
  • 1235798 2025-007
    Material Weakness Repeat
  • 1235799 2025-007
    Material Weakness Repeat
  • 1235800 2025-007
    Material Weakness Repeat
  • 1235801 2025-007
    Material Weakness Repeat
  • 1235802 2025-007
    Material Weakness Repeat
  • 1235803 2025-007
    Material Weakness Repeat
  • 1235804 2025-007
    Material Weakness Repeat
  • 1235805 2025-007
    Material Weakness Repeat
  • 1235806 2025-007
    Material Weakness Repeat
  • 1235807 2025-007
    Material Weakness Repeat
  • 1235808 2025-007
    Material Weakness Repeat
  • 1235809 2025-007
    Material Weakness Repeat
  • 1235810 2025-007
    Material Weakness Repeat
  • 1235811 2025-007
    Material Weakness Repeat
  • 1235812 2025-007
    Material Weakness Repeat
  • 1235813 2025-007
    Material Weakness Repeat
  • 1235814 2025-007
    Material Weakness Repeat
  • 1235815 2025-007
    Material Weakness Repeat
  • 1235816 2025-007
    Material Weakness Repeat
  • 1235817 2025-007
    Material Weakness Repeat
  • 1235818 2025-007
    Material Weakness Repeat
  • 1235819 2025-007
    Material Weakness Repeat
  • 1235820 2025-007
    Material Weakness Repeat
  • 1235821 2025-007
    Material Weakness Repeat
  • 1235822 2025-007
    Material Weakness Repeat
  • 1235823 2025-007
    Material Weakness Repeat
  • 1235824 2025-007
    Material Weakness Repeat
  • 1235825 2025-007
    Material Weakness Repeat
  • 1235826 2025-007
    Material Weakness Repeat
  • 1235827 2025-007
    Material Weakness Repeat
  • 1235828 2025-007
    Material Weakness Repeat
  • 1235829 2025-007
    Material Weakness Repeat
  • 1235830 2025-007
    Material Weakness Repeat
  • 1235831 2025-007
    Material Weakness Repeat
  • 1235832 2025-007
    Material Weakness Repeat
  • 1235833 2025-007
    Material Weakness Repeat
  • 1235834 2025-007
    Material Weakness Repeat
  • 1235835 2025-007
    Material Weakness Repeat
  • 1235836 2025-007
    Material Weakness Repeat
  • 1235837 2025-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.778 GRANTS TO STATES FOR MEDICAID $1.30M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $427,702
93.788 OPIOID STR $383,832
10.557 WIC SPECIAL SUPPLEMENTAL NUTRITION PROGRAM FOR WOMEN, INFANTS, AND CHILDREN $327,995
93.563 CHILD SUPPORT SERVICES $183,439
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $147,464
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $125,480
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $99,477
84.181 SPECIAL EDUCATION-GRANTS FOR INFANTS AND FAMILIES $97,225
93.090 GUARDIANSHIP ASSISTANCE $85,743
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $81,443
93.658 FOSTER CARE TITLE IV-E $67,978
20.513 ENHANCED MOBILITY OF SENIORS AND INDIVIDUALS WITH DISABILITIES $60,779
93.052 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE III, PART E $53,901
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $48,538
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $35,137
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $25,794
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $25,644
93.044 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART B, GRANTS FOR SUPPORTIVE SERVICES AND SENIOR CENTERS $25,592
16.540 JUVENILE JUSTICE AND DELINQUENCY PREVENTION $20,538
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $19,324
20.601 ALCOHOL IMPAIRED DRIVING COUNTERMEASURES INCENTIVE GRANTS I $19,201
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $17,981
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $13,308
20.609 SAFETY BELT PERFORMANCE GRANTS $12,390
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $11,696
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $11,082
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $11,029
66.032 STATE AND TRIBAL INDOOR RADON GRANTS $9,729
93.324 STATE HEALTH INSURANCE ASSISTANCE PROGRAM $9,364
93.071 MEDICARE ENROLLMENT ASSISTANCE PROGRAM $8,506
93.043 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART D, DISEASE PREVENTION AND HEALTH PROMOTION SERVICES $8,353
93.268 IMMUNIZATION COOPERATIVE AGREEMENTS $6,946
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $6,890
93.667 SOCIAL SERVICES BLOCK GRANT $4,231
93.758 PREVENTIVE HEALTH AND HEALTH SERVICES BLOCK GRANT FUNDED SOLELY WITH PREVENTION AND PUBLIC HEALTH FUNDS (PPHF) $3,986
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $3,109
16.543 MISSING CHILDREN'S ASSISTANCE $2,807
97.039 HAZARD MITIGATION GRANT $1,669
93.070 ENVIRONMENTAL PUBLIC HEALTH AND EMERGENCY RESPONSE $1,453
93.354 PUBLIC HEALTH EMERGENCY RESPONSE: COOPERATIVE AGREEMENT FOR EMERGENCY RESPONSE: PUBLIC HEALTH CRISIS RESPONSE $107