FAC Explorer

Finding 370332 (2023-003)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-02-23
Audit: 291959
Organization: City of Detroit, Michigan (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The City lacked adequate controls to oversee contractor eligibility determinations for the WIC program, leading to a material weakness in compliance.
  • Impacted Requirements: This finding violates 2 CFR 200.303(a), which mandates effective internal controls over federal awards to ensure compliance with regulations and award terms.
  • Recommended Follow-Up: The City should establish oversight procedures to review contractor work on eligibility determinations and ensure compliance with federal requirements.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Federal Award Identification Number and Year - 213MI013W5003, 212MI003W1003, program years 2022 and 2023 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness Repeat Finding - Yes 2022-006 Criteria - Per 2 CFR 200.303(a), the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government," issued by the Comptroller General of the United States, or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition - The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The City entered into an agreement with a contractor to perform eligibility intake for WIC applicants. While the City arranges for the contractor to perform the intake function, the City is fully responsible for the federal compliance for the eligibility determination process. Testing revealed that the contractor's staff performed both initial and secondary reviews during the intake process. Procedures further revealed that the City did not have any control in place to exercise its oversight responsibility of the grant and relied solely on the contractor's eligibility determinations through May 2023. Cause and Effect - In the current year, the City contracted with a contractor to perform the eligibility intake function and other programmatic decisions for WIC. However, the City did not implement controls to ensure eligibility conclusions reached by the contractor were in compliance with the terms and conditions of the award. Without a review of the contractor's procedures to determine participant eligibility, ineligible participants could receive program benefits. Recommendation - We recommend the City develop oversight procedures to review the work completed by contractors, which pertains to compliance requirements and programmatic decisions, in this case, participant eligibility determination. Views of Responsible Officials and Planned Corrective Actions - The City has implemented controls to ensure that the Health Department provides oversight over the contractors. A new contract was in place in May, and the Health Department hired a WIC program director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.

Categories

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 370328 2023-012
    Material Weakness Repeat
  • 370329 2023-012
    Material Weakness Repeat
  • 370330 2023-012
    Material Weakness Repeat
  • 370331 2023-003
    Material Weakness Repeat
  • 370333 2023-003
    Material Weakness Repeat
  • 370334 2023-003
    Material Weakness Repeat
  • 370335 2023-004
    Material Weakness
  • 370336 2023-004
    Material Weakness
  • 370337 2023-004
    Material Weakness
  • 370338 2023-004
    Material Weakness
  • 370339 2023-005
    Material Weakness
  • 370340 2023-006
    Material Weakness
  • 370341 2023-006
    Material Weakness
  • 370342 2023-006
    Material Weakness
  • 370343 2023-006
    Material Weakness
  • 370344 2023-006
    Material Weakness
  • 370345 2023-006
    Material Weakness
  • 370346 2023-006
    Material Weakness
  • 370347 2023-006
    Material Weakness
  • 370348 2023-006
    Material Weakness
  • 370349 2023-006
    Material Weakness
  • 370350 2023-006
    Material Weakness
  • 370351 2023-006
    Material Weakness
  • 370352 2023-006
    Material Weakness
  • 370353 2023-006
    Material Weakness
  • 370354 2023-006
    Material Weakness
  • 370355 2023-007
    Material Weakness Repeat
  • 370356 2023-007
    Material Weakness Repeat
  • 370357 2023-007
    Material Weakness Repeat
  • 370358 2023-007
    Material Weakness Repeat
  • 370359 2023-008
    Material Weakness
  • 370360 2023-008
    Material Weakness
  • 370361 2023-008
    Material Weakness
  • 370362 2023-008
    Material Weakness
  • 370363 2023-009
    Significant Deficiency
  • 370364 2023-009
    Significant Deficiency
  • 370365 2023-010
    Material Weakness
  • 370366 2023-010
    Material Weakness
  • 370367 2023-010
    Material Weakness
  • 370368 2023-010
    Material Weakness
  • 370369 2023-011
    Material Weakness
  • 370370 2023-011
    Material Weakness
  • 370371 2023-011
    Material Weakness
  • 946770 2023-012
    Material Weakness Repeat
  • 946771 2023-012
    Material Weakness Repeat
  • 946772 2023-012
    Material Weakness Repeat
  • 946773 2023-003
    Material Weakness Repeat
  • 946774 2023-003
    Material Weakness Repeat
  • 946775 2023-003
    Material Weakness Repeat
  • 946776 2023-003
    Material Weakness Repeat
  • 946777 2023-004
    Material Weakness
  • 946778 2023-004
    Material Weakness
  • 946779 2023-004
    Material Weakness
  • 946780 2023-004
    Material Weakness
  • 946781 2023-005
    Material Weakness
  • 946782 2023-006
    Material Weakness
  • 946783 2023-006
    Material Weakness
  • 946784 2023-006
    Material Weakness
  • 946785 2023-006
    Material Weakness
  • 946786 2023-006
    Material Weakness
  • 946787 2023-006
    Material Weakness
  • 946788 2023-006
    Material Weakness
  • 946789 2023-006
    Material Weakness
  • 946790 2023-006
    Material Weakness
  • 946791 2023-006
    Material Weakness
  • 946792 2023-006
    Material Weakness
  • 946793 2023-006
    Material Weakness
  • 946794 2023-006
    Material Weakness
  • 946795 2023-006
    Material Weakness
  • 946796 2023-006
    Material Weakness
  • 946797 2023-007
    Material Weakness Repeat
  • 946798 2023-007
    Material Weakness Repeat
  • 946799 2023-007
    Material Weakness Repeat
  • 946800 2023-007
    Material Weakness Repeat
  • 946801 2023-008
    Material Weakness
  • 946802 2023-008
    Material Weakness
  • 946803 2023-008
    Material Weakness
  • 946804 2023-008
    Material Weakness
  • 946805 2023-009
    Significant Deficiency
  • 946806 2023-009
    Significant Deficiency
  • 946807 2023-010
    Material Weakness
  • 946808 2023-010
    Material Weakness
  • 946809 2023-010
    Material Weakness
  • 946810 2023-010
    Material Weakness
  • 946811 2023-011
    Material Weakness
  • 946812 2023-011
    Material Weakness
  • 946813 2023-011
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $15.64M
93.914 Hiv Emergency Relief Project Grants $7.94M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $5.18M
21.023 Covid-19 Emergency Rental Assistance Program $4.25M
14.231 Covid-19 - Emergency Solutions Grant Program $3.60M
66.468 Capitalization Grants for Drinking Water State Revolving Funds $3.09M
14.231 Emergency Solutions Grant Program $2.69M
14.241 Housing Opportunities for Persons with Aids $2.65M
93.686 Ending the Hiv Epidemic: A Plan for America — Ryan White Hiv/aids Program Parts A and B (b) $2.38M
93.391 Covid-19 - Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $1.86M
16.835 Body Worn Camera Policy and Implementation $1.64M
14.905 Lead Hazard Reduction Demonstration Grant Program $1.62M
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $1.25M
14.239 Home Investment Partnerships Program $950,437
20.205 Highway Planning and Construction $754,881
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $724,340
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $634,392
14.889 Choice Neighborhoods Implementation Grants $620,056
93.268 Immunization Cooperative Agreements $560,088
93.767 Children's Health Insurance Program $502,860
20.500 Federal Transit_capital Investment Grants $479,997
66.458 Capitalization Grants for Clean Water State Revolving Funds $358,544
15.904 Historic Preservation Fund Grants-in-Aid $341,810
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $323,424
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $314,304
16.812 Second Chance Act Reentry Initiative $305,825
20.507 Federal Transit_capital Investment Grants $280,691
14.241 Covid-19 - Housing Opportunities for Persons with Aids $276,889
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $269,928
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $249,351
97.067 Homeland Security Grant Program $226,120
14.913 Healthy Homes Production Program $204,014
20.521 New Freedom Program $185,428
93.778 Medical Assistance Program $183,716
97.056 Port Security Grant Program $167,449
20.507 Covid-19 - Federal Transit_capital Investment Grants $162,637
93.217 Family Planning_services $139,468
14.239 Covid-19 - Home Investment Partnerships Program $118,832
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $113,778
97.044 Assistance to Firefighters Grant $98,793
14.218 Community Development Block Grants/entitlement Grants $97,940
93.917 Hiv Care Formula Grants $87,682
93.069 Public Health Emergency Preparedness $78,692
10.558 Child and Adult Care Food Program $73,350
93.136 Covid-19 - Injury Prevention and Control Research and State and Community Based Programs $70,555
10.559 Summer Food Service Program for Children $65,974
16.838 Comprehensive Opioid Abuse Site-Based Program $65,250
93.268 Covid-19 - Immunization Cooperative Agreements $64,574
16.817 Byrne Criminal Justice Innovation Program $55,614
16.710 Public Safety Partnership and Community Policing Grants $45,259
16.753 Congressionally Recommended Awards $40,120
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $38,105
16.738 Edward Byrne Memorial Justice Assistance Grant Program $37,787
97.042 Emergency Management Performance Grants $30,248
20.600 State and Community Highway Safety $22,431
15.929 Save America's Treasures $19,300
16.588 Violence Against Women Formula Grants $16,412
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $11,668
16.922 Equitable Sharing Program $10,301
20.516 Job Access and Reverse Commute Program $7,796
93.361 Covid-19 - Nursing Research $7,305
45.024 Promotion of the Arts_grants to Organizations and Individuals $5,177
93.994 Maternal and Child Health Services Block Grant to the States $2,622
20.616 National Priority Safety Programs $2,139
93.931 Sdoh Planning $407
16.575 Crime Victim Assistance $110