FAC Explorer

Finding 30623 (2022-011)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-04-02
Audit: 26048
Organization: Charter County of Wayne, Michigan (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The County lacks adequate controls to ensure compliance with eligibility standards when contractors handle eligibility determinations.
  • Impacted Requirements: Compliance with 2 CFR 200.501(g) and MI-WIC Policy regarding separation of duties in eligibility processes.
  • Recommended Follow-Up: Implement a review process by a County representative for contractor eligibility determinations, utilizing state-provided audit tools.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - 10.557, U.S. Department of Agriculture ? WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year E2022241300; E20223664-00 Pass through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.501(g), Federal award compliance requirements normally do not pass through to the contractors. However, the grant recipient is responsible for ensuring compliance for procurement transactions which are structured such that the contractor is responsible for program compliance or the contractor's records must be reviewed to determine program compliance. Condition - Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there are no questioned costs. Context - During eligibility testing, we noted 16 out of 40 eligibility samples whereby employers of the contractor performed both the intake and the certification and review function, with no further review by a County representative. Cause and Effect - The County is subject to the MI-WIC Policy issued by the Michigan Department of Health and Human Services, which stresses the importance of maintaining appropriate separation of duties when performing the intake and certification of eligible program participants. While the County has designed its controls in conjunction with the MI-WIC Policy guidance, these controls are not adequate to ensure compliance with Unifor m Guidance, which requires the County have controls in place to ensure that a representative of the County performs a review of eligibility intake and certification performed by contractor employees. Recommendation - We recommend the County implement a process by which a County representative performs a review of contractor eligibility determinations. Views of Responsible Officials and Corrective Action Plan - Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor.

Corrective Action Plan

Federal Program: ALN 10.557, U.S. Department of Agriculture (? WIC Special Supplemental Nutrition Program for Women, Infants, and Children) Condition per Auditor: Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Planned Corrective Action: Management will implement and follow a process of reviewing of eligibility intake and certification performed by contractor employees by internal County representative. This will be completed by the internal county WIC Compliance Manager or designee and will utilize the audit tools provided by the state that includes monitoring of eligibility intake and certification. The WIC Compliance Manager will request contractors to complete audit reporting templates monthly and flag any items in need of further investigation with the contractor. Anticipated Completion Date: 9/30/2024 Responsible Contact Person: Natalie Dean Wood and Dr. Avani Sheth

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility Material Weakness Reporting

Other Findings in this Audit

  • 30624 2022-011
    Material Weakness
  • 30625 2022-014
    Material Weakness
  • 30626 2022-014
    Material Weakness
  • 30627 2022-014
    Material Weakness
  • 30628 2022-013
    Material Weakness
  • 30629 2022-012
    Material Weakness
  • 30630 2022-012
    Material Weakness
  • 30631 2022-014
    Material Weakness
  • 30632 2022-014
    Material Weakness
  • 30633 2022-014
    Material Weakness
  • 30634 2022-014
    Material Weakness
  • 607065 2022-011
    Material Weakness
  • 607066 2022-011
    Material Weakness
  • 607067 2022-014
    Material Weakness
  • 607068 2022-014
    Material Weakness
  • 607069 2022-014
    Material Weakness
  • 607070 2022-013
    Material Weakness
  • 607071 2022-012
    Material Weakness
  • 607072 2022-012
    Material Weakness
  • 607073 2022-014
    Material Weakness
  • 607074 2022-014
    Material Weakness
  • 607075 2022-014
    Material Weakness
  • 607076 2022-014
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.023 Covid-19 - Emergency Rental Assistance Program $17.39M
93.268 Covid-19 - Immunization Cooperative Agreements $2.75M
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.54M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.12M
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $1.63M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.45M
21.019 Covid-19 - Coronavirus Relief Fund $1.41M
14.231 Covid-19 - Emergency Solutions Grant Program $1.09M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $930,530
16.575 Crime Victim Assistance $797,468
93.045 Covid-19 - Special Programs for the Aging_title Iii, Part C_nutrition Services $769,122
93.658 Foster Care_title IV-E $747,040
93.563 Child Support Enforcement $727,984
93.053 Nutrition Services Incentive Program $640,262
20.205 Highway Planning and Construction $575,930
93.224 Covid-19 - Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $535,456
93.268 Immunization Cooperative Agreements $476,913
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $471,717
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $433,426
66.458 Capitalization Grants for Clean Water State Revolving Funds $418,968
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $409,291
93.137 Covid-19 - Community Programs to Improve Minority Health Grant Program $359,764
16.588 Violence Against Women Formula Grants $357,513
14.218 Community Development Block Grants/entitlement Grants $300,000
15.904 Historic Preservation Fund Grants-in-Aid $299,519
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $298,182
16.606 State Criminal Alien Assistance Program $278,125
14.239 Home Investment Partnerships Program $243,912
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $214,165
93.940 Hiv Prevention Activities_health Department Based $144,819
93.889 National Bioterrorism Hospital Preparedness Program $129,470
97.012 Boating Safety Financial Assistance $93,400
93.767 Children's Health Insurance Program $90,865
16.036 Prosecuting Cold Cases Using Dna $74,204
97.042 Emergency Management Performance Grants $67,044
95.001 High Intensity Drug Trafficking Areas Program $66,169
16.034 Covid-19 - Coronavirus Emergency Supplemental Funding Program $58,758
14.231 Emergency Solutions Grant Program $56,002
16.825 Smart Prosecution Initiative $43,202
93.778 Medical Assistance Program $32,310
16.585 Drug Court Discretionary Grant Program $24,439
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $22,079
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $20,664
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $18,643
93.471 Title IV-E Kinship Navigator Program (a) $16,511
16.738 Edward Byrne Memorial Justice Assistance Grant Program $15,218
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $14,012
93.586 Covid-19 - State Court Improvement Program $13,379
20.616 National Priority Safety Programs $11,411
66.469 Great Lakes Program $8,566
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $8,254
16.833 National Sexual Assault Kit Initiative $5,915
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $5,213
97.067 Homeland Security Grant Program $3,535
14.239 Covid-19 Home Investment Partnerships Program $2,111
93.994 Maternal and Child Health Services Block Grant to the States $272
66.468 Capitalization Grants for Drinking Water State Revolving Funds $266