Finding Text
2022-001 - Eligibility, Repeat Finding - see prior year finding 2021-001 Funding Agency: United States Department of Agriculture, Passed through the Michigan Department of Education Title: Food Distribution Cluster Assistance Listing Number: 10.565 Award Number: 220001006C Award Period: October 1, 2021 through September 30, 2022 Questioned Costs: None How Questioned Costs Were Computed: N/A Criteria or Specific Requirement: A local agency certifies households as eligible to receive a CSFP food package by applying categorical and income eligibility criteria. Categorical eligibility requirements include elderly (persons at least 60 years of age) and women, infants, and children. Income eligibility requirements for elderly persons (which are Dickinson-Iron Community Services Agency's primary population of participants) must have income at or below 130 percent of the federal poverty level. The local agency certifies households eligible to receive CSFP assistance by applying the federal poverty guidelines to the household. The local agency is required to design and implement appropriate internal controls over compliance to prevent, or detect and correct noncompliance on a timely basis. Condition: In our sample of 40 individuals tested for eligibility compliance, five individuals did not have original applications on file with applicant signatures. The households for which these individuals applied were eligible for services and the original applications had been entered into an electronic data base for tracking, but the original applications were unable to be located. Context: Dickinson-Iron Community Services Agency, much like many nonprofit organizations, experienced significant disruption and reorganization during the COVID-19 pandemic. Cause: Due to turnover in staffing, Dickinson-Iron Community Services Agency failed to follow through on their corrective action plan for our finding in 2021. The Organization failed to design and operate internal control to effectively maintain original records of eligibility and to effectively ensure that eligibility was being determined properly at all sites. Effect: When internal controls over compliance are ineffectively executed, there is a risk that ineligible individuals will be served. Auditor's Recommendation: Wipfli recommends that Dickinson-Iron Community Services Agency maintain original application information or design a procedure in the electronic tracking system to ensure that all relevant original information has been reviewed and evidence is obtained of that review to ensure the existence of the applicant. View of Responsible Official: We agree with the finding and are committed to implementing corrective action.