Finding 442906 (2022-001)

- Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2023-09-04
Audit: 312518
Organization: Beacon Health System, Inc. (IN)

AI Summary

  • Core Issue: The Corporation's paperless system limits the ability to verify eligibility documentation for the WIC program, leading to compliance testing challenges.
  • Impacted Requirements: Eligibility criteria for WIC, including proof of identity, residency, and income, are not retained, affecting compliance with federal guidelines.
  • Recommended Follow-Up: Review internal controls and consider implementing a process to retain necessary documentation to ensure compliance and support future audits.

Finding Text

Identification of the Federal Program:Federal Grantor: U.S. Department of Agriculture Food and Nutrition ServiceAssistance Listing No.: 10.557 ? Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)Pass-Through Entity: Indiana State Department of HealthPass-Through Award Numbers: 3610-572900-142500 (21), 3610-572900-142500 (22)Award Years: 10/1/21?9/30/22 and 10/1/22-9/30/23Criteria or Specific Requirement (including statutory, regulatory or other citation):Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the following eligibility criteria (7 CFR Sections 246.7(c), (d), (e), (g), and (l)):(a) Categorical ? Eligibility is restricted to pregnant, postpartum, and breast-feeding women; infants; and children up to their fifth birthday (7 CFR Sections 246.2 (definition of each category) and 246.7(c)).(b) Identity and Residency ? Except in limited circumstances, WIC applicants must be physically present for eligibility screenings and must provide proof of identity. An applicant must also meet the state agency residency requirement. Except in the case of Indian state agencies, the applicant must reside in the jurisdiction of the state. Indian state agencies may require applicants to reside within their jurisdiction.(c) Income ? An applicant must meet an income standard established by the state agency or be determined to be automatically (adjunctively) income-eligible based on documentation of his/her eligibility, or certain family members? eligibility, for the following federal programs: (1) Temporary Assistance for Needy Families, (2) Medicaid, or (3) Supplemental Nutrition Assistance Program (formerly the Food Stamp Program). State agencies may also determine an individual to be automatically income-eligible, based on documentation of his/her eligibility for certain state-administered programs.(d) Nutritional Risk ? A competent professional authority (e.g., physician, nutritionist, registered nurse, or other health professional) must determine that the applicant is at nutritional risk. While the broad guidelines for determining nutritional risk are set forth in WIC legislation and regulations, the specific allowable nutritional risk criteria are defined in WIC policy guidance, which is updated periodically. Each state agency may choose which allowable nutritional risk criteria will be used to determine eligibility.When an applicant meets all eligibility criteria, he/she is determined by WIC clinic staff to be eligible for program benefits. Certification periods are assigned to each participant based on categorical status for women, infants, and children (7 CFR Section 246.7(g)).A WIC local agency assigns each eligible person a priority classification according to the classification system described in 7 CFR Section 246.7(e)(4). A person?s priority assignment reflects the severity of his/her nutritional risk. If the local agency cannot immediately place the person on the program for lack of an available caseload slot, the person is placed on a waiting list. Caseload vacancies are filled from the waiting list in priority classification order. State agencies are expected to target program outreach and caseload management efforts toward persons at greatest nutritional risk (i.e., those in the highest priority classifications).Pregnant women are certified for the duration of their pregnancies and for up to six weeks postpartum. Breast-feeding women may be certified approximately every six months, up to one year postpartum, or until the woman ceases breast-feeding, whichever occurs first (7 CFR Section 246.7(g)(1)). Infants are certified at intervals of approximately six months, except that infants under six months of age may be certified for a period extending up to the child?s first birthday, provided the quality and accessibility of health care services are not diminished. Children are certified for six-month intervals ending with the last day of the month in which the child reaches his/her fifth birthday. State agencies also have the option to certify children for a period of one year if the state agency ensures that the child receives the required health and nutrition assessments (7 CFR Section 246.7(g)(1)). Non-breast-feeding women are certified for up to six months postpartum. All categories of participants may be certified up to the last day of the last month of the certification period (7 CFR Section 246.7(g)(1)).Condition:The Corporation screens applicants for eligibility by following the state of Indiana guidelines as provided through the INWIC system used to enter, track, and store information about applicants. Based on guidance contained in 7 CFR Section 246, states were encouraged to move to a paperless system. Specifically, federal guidance contained in 7 CFR 246.7 (i)(4) and (5)(i) outlines acceptable documentation to be included on certification forms as ?a description of the document(s) used to determine residency and identity or a copy of the document(s) used or the applicants written statement when no documentation exists,? and ?a description of the document(s) used to determine income eligibility or a copy of the document(s) in the file.? The state of Indiana has followed that guidance and does not require the Corporation to retain copies of an applicant?s proof of residence, income, etc., regarding eligibility. Therefore, we were not able to test internal controls over compliance or compliance over the eligibility compliance requirement through re-performance and have issued a qualified opinion based on the scope limitations.Cause:The Corporation follows a paperless system as supported by the state of Indiana and the U.S. Department of Agriculture. The state does not require third-party supporting documentation of eligibility determinations to be retained.Effect or potential effect:Due to the online nature of the eligibility system, the program does not have documentation available for the audit team to test compliance with the eligibility requirement. A scope limitation qualified opinion was issued for Assistance Listing 10.557, as we were unable to obtain sufficient documentation supporting the compliance of the Corporation regarding eligibility.Questioned Costs:None.Context:Federal expenditures reported in the schedule of expenditures of federal awards for Assistance Listing 10.557 totaled $1,703,252 for the year ended December 31, 2022.Identification as a repeat finding, if applicable:Yes. Prior year findings 2021-001.Recommendation:No further follow-up is required, as management of the Corporation is following the applicable guidance.Views of responsible officials:Management agrees with the finding. No changes in our current procedures are required as we are following the State requirements.

Corrective Action Plan

Finding 2022-001 Scope Limitation ? EligibilityA scope limitation qualified opinion was issued for Assistance Listing 10.557 as the auditors were unable to obtain sufficient documentation supporting the compliance of the Corporation regarding eligibility. The Corporation uses a paperless system as supported by the State of Indiana and the U.S. Department of Agriculture. Third-party documentation is reviewed by the Corporation at the time the initial eligibility determination of a WIC participant is made. However, due to the paperless system implemented in 2007, these records are not retained. The Corporation?s process for eligibility determination is as follows:1. A (potential) participant comes into the WIC clinic2. A clerk verifies information (by looking and checking the appropriate boxes on the screen)a. Proof of identification (driver?s license, birth certificate, hospital birth record, etc.)b. Proof of residence (bill, lease, driver?s license, etc.)c. Proof of incomei. Working ? 30 days of pay stubsii. Medicaid ? card needed3. All of the above information is entered into the State of Indiana?s systema. System automatically determines eligibilityi. If yes ? they continue with appointmentii. If no ? they get a letter explaining reason why (over income, etc.)Compliance with State of Indiana participant eligibility requirements is the responsibility of Leslie Miller, WIC Coordinator. As the Corporation follows the State of Indiana?s paperless system as described above, no further corrective action will be taken.

Categories

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

Other Findings in this Audit

  • 442907 2022-004
    Material Weakness
  • 442908 2022-002
    Material Weakness
  • 442909 2022-002
    Material Weakness
  • 442910 2022-005
    Material Weakness
  • 442911 2022-006
    Significant Deficiency
  • 1019348 2022-001
    - Repeat
  • 1019349 2022-004
    Material Weakness
  • 1019350 2022-002
    Material Weakness
  • 1019351 2022-002
    Material Weakness
  • 1019352 2022-005
    Material Weakness
  • 1019353 2022-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $21.03M
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $14.52M
93.011 National Organizations of State and Local Officials $2.23M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $1.70M
93.461 Covid-19 Hrsa Covid-19 Claims Reimbursement for the Uninsured Program and the Covid-19 Coverae Assistance Fund $682,332
93.788 Opioid Str $550,335
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $24,729