Finding 515573 (2023-008)

Significant Deficiency Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-12-18
Audit: 333283
Organization: Unity Health Care, Inc. (MD)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The Corporation failed to provide evidence that eligibility assessments for WIC benefits were properly reviewed, leading to potential ineligibility of beneficiaries.
  • Impacted Requirements: Key eligibility criteria related to Category, Identity and Residency, Income, and Nutritional Risk were not adequately documented or verified.
  • Recommended Follow-up: Establish formal internal controls and documentation processes to ensure thorough review of eligibility assessments and compliance with WIC program requirements.

Finding Text

Criteria: Applicants for WIC program benefits are screened at WIC clinic sites to determine their WIC eligibility. To be certified eligible, they must meet the eligibility criteria defined at 7 CFR sections 246.7(c), (d), (e), (g), and (l) related to Category, Identity and Residency, Income, and Nutritional Risk. Condition: During our testing of eligibility, the Corporation was unable to provide support that eligibility assessments performed were reviewed. Below is a summary of our findings: • For 1 of the 40 samples, proper segregation of duties was not maintained as the staff person who determined income eligibility was the same staff person who completed the medical risk assessment. • For 3 of the 40 samples, the Corporation was unable to provide support to verify the applicant signed the Rights and Obligations statement. • For all 40 samples, the Corporation was unable to provide support that the eligibility assessments performed were reviewed. Cause: The Corporation did not have formal policies and procedures over eligibility. Effect or Potential Effect: Lack of strict adherence to documentation requirements may have resulted in the Organization providing benefits to ineligible beneficiaries. Questioned costs: None Context: We tested a sample of 40 participants determined to be eligible and noted the Corporation was not able to produce sufficient and appropriate evidence that eligibility assessments performed were reviewed, and found exceptions as noted in the condition. This is a condition identified per review of the Corporation’s compliance with specified requirements using a statistically valid sample. Repeat finding: This is a repeat finding from prior year. This was reported as finding 2022-014 in the 2022 report. Recommendation: We recommend the Corporation establish formal internal controls, and documentation of their performance, relating to assessing eligibility of participants. View of Responsible Officials: Due to turnover of several key financial executives and personnel and lack of formal documentation of current policies and procedures, the Corporation did not maintain sufficient or appropriate evidence that eligibility assessments performed were reviewed.

Corrective Action Plan

Management Response #2023-008: Due to staff turnover, the Corporation did not consistently enforce segregation of duties between the individual responsible for determining income eligibility and the one completing the medical risk assessment. The Corporation also failed to provide sufficient support to verify that the applicant signed the Rights and Obligations statement. Corrective Action Plan: • All eligibility verification data, including screenshots and signed Rights and Obligations statements, will be stored in a centralized, secure shared drive maintained and managed by the WIC Director to ensure it is protected with limited access and password protection. The drive will be organized using a de-identified naming convention to ensure privacy while maintaining ease of access for authorized staff. • To maintain a robust system of checks and balances, tasks related to eligibility verification and documentation will be divided among different team members. This separation will prevent any one individual from having full control over the process, reducing the risk of oversight or potential errors. • The WIC Department’s policy and procedure manuals will be revised and updated to include the new eligibility verification process. • To ensure adherence to the new protocols, periodic audits and review sessions will be conducted by the WIC Director or designated compliance staff to verify that documentation is being properly maintained and that all procedures are followed. Staff will be required to undergo refresher training sessions as needed to reinforce the updated protocols and best practices. Responsible Party: Tracy Harrison, COO

Categories

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

  • 515547 2023-004
    Material Weakness Repeat
  • 515548 2023-005
    Material Weakness Repeat
  • 515549 2023-006
    Material Weakness Repeat
  • 515550 2023-007
    Significant Deficiency Repeat
  • 515551 2023-004
    Material Weakness Repeat
  • 515552 2023-005
    Material Weakness Repeat
  • 515553 2023-006
    Material Weakness Repeat
  • 515554 2023-007
    Significant Deficiency Repeat
  • 515555 2023-004
    Material Weakness Repeat
  • 515556 2023-005
    Material Weakness Repeat
  • 515557 2023-006
    Material Weakness Repeat
  • 515558 2023-009
    Significant Deficiency Repeat
  • 515559 2023-004
    Material Weakness
  • 515560 2023-007
    Significant Deficiency
  • 515561 2023-004
    Material Weakness Repeat
  • 515562 2023-005
    Material Weakness Repeat
  • 515563 2023-006
    Material Weakness Repeat
  • 515564 2023-009
    Significant Deficiency Repeat
  • 515565 2023-004
    Material Weakness Repeat
  • 515566 2023-005
    Material Weakness Repeat
  • 515567 2023-006
    Material Weakness Repeat
  • 515568 2023-009
    Significant Deficiency Repeat
  • 515569 2023-004
    Material Weakness Repeat
  • 515570 2023-005
    Material Weakness Repeat
  • 515571 2023-006
    Material Weakness Repeat
  • 515572 2023-007
    Significant Deficiency Repeat
  • 515574 2023-009
    Significant Deficiency Repeat
  • 1091989 2023-004
    Material Weakness Repeat
  • 1091990 2023-005
    Material Weakness Repeat
  • 1091991 2023-006
    Material Weakness Repeat
  • 1091992 2023-007
    Significant Deficiency Repeat
  • 1091993 2023-004
    Material Weakness Repeat
  • 1091994 2023-005
    Material Weakness Repeat
  • 1091995 2023-006
    Material Weakness Repeat
  • 1091996 2023-007
    Significant Deficiency Repeat
  • 1091997 2023-004
    Material Weakness Repeat
  • 1091998 2023-005
    Material Weakness Repeat
  • 1091999 2023-006
    Material Weakness Repeat
  • 1092000 2023-009
    Significant Deficiency Repeat
  • 1092001 2023-004
    Material Weakness
  • 1092002 2023-007
    Significant Deficiency
  • 1092003 2023-004
    Material Weakness Repeat
  • 1092004 2023-005
    Material Weakness Repeat
  • 1092005 2023-006
    Material Weakness Repeat
  • 1092006 2023-009
    Significant Deficiency Repeat
  • 1092007 2023-004
    Material Weakness Repeat
  • 1092008 2023-005
    Material Weakness Repeat
  • 1092009 2023-006
    Material Weakness Repeat
  • 1092010 2023-009
    Significant Deficiency Repeat
  • 1092011 2023-004
    Material Weakness Repeat
  • 1092012 2023-005
    Material Weakness Repeat
  • 1092013 2023-006
    Material Weakness Repeat
  • 1092014 2023-007
    Significant Deficiency Repeat
  • 1092015 2023-008
    Significant Deficiency Repeat
  • 1092016 2023-009
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $5.29M
93.224 Community Health Centers $2.85M
93.788 Opioid Str $2.05M
93.217 Family Planning Services $1.47M
93.914 Hiv Emergency Relief Project Grants $1.34M
93.526 Fip Verification $898,419
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $862,759
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $459,480
93.837 Cardiovascular Diseases Research $410,473
93.917 Hiv Care Formula Grants $409,149
93.994 Maternal and Child Health Services Block Grant to the States $328,090
93.427 Provision of Technical Assistance and Training Activities to Assure Comprehensive Cancer Control Outcomes. $113,387
93.426 The National Cardiovascular Health Program $102,468
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $102,041
93.855 Allergy and Infectious Diseases Research $7,112