FAC Explorer

Finding 551130 (2024-006)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 352056
Organization: County of Solano (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to maintain necessary eligibility documentation for program participants, leading to a material weakness in internal controls and noncompliance.
  • Impacted Requirements: Compliance with the 2024 OMB guidelines for eligibility records, including documentation for eligibility determinations and redeterminations.
  • Recommended Follow-Up: Establish procedures to retain critical documentation not kept in WIC WISE and enhance policies for obtaining required forms during applications and redeterminations.

Finding Text

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified the following: 1. Five (5) instances out of 60 cases were missing all eligibility documentation. This included the documentation of the determination of eligibility and redetermination in the period under audit. The missing documentation included the records to evidence compliance with the eligibility criteria. 2. Two (2) instances out of 60 cases were missing the Self Declaration Statement form when the applicant was unable to provide acceptable documentation for proof of income, proof of address, or proof of identification. Cause: The County relies on the State of California Department of Public Health eligibility and documentation system, Women, Infant, and Children Web Information System Exchange (WIC WISE) to retain the case records. Management stated that WIC WISE automatically deletes the documentation for children 6 months after the child reaches 5 years old, and therefore was not available for the selected cases. The County’s policies and procedures did not ensure that the Self Declaration Statements were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 60 program participants out of a population of 9,060 were selected for testing. The five (5) and two (2) instances identified in the condition section above were part of the same population of 60 participants. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to retain documentation to evidence its compliance with program eligibility requirements for those documents which will not be retained in WIC WISE. We also recommend that the county strengthen its current policies and procedures with regards to obtaining the required forms at the initial application and periodic redeterminations. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Corrective Action Plan

Federal Agency: U.S. Department of Agriculture Program/Cluster: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number: 10.557 Pass‐through: California Department of Public Health Award No. and Year: 22-10294 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Condition #1. Five (5) instances out of 60 cases were missing all eligibility documentation. This included the documentation of the determination of eligibility and redetermination in the period under audit. The missing documentation included the records to evidence compliance with the eligibility criteria. Condition #2. Two (2) instances out of 60 cases were missing the Self Declaration Statement form when the applicant was unable to provide acceptable documentation for proof of income, proof of address, or proof of identification. Response to Condition #1 Per California Department of Public Health, Women, Infant, Children division (CDPH/WIC), the categories of non-breastfeeding, breastfeeding, and partially breastfeeding women files remain accessible to the local agency. For children five years of age, the files are purged six months after the fifth birthday. The WIC WISE records for the 5 files were not available due to the file purge by CDPH/WIC, therefore the auditor was unable to determine compliance to eligibility requirements for each of the five files. The auditor suggests the local agency retain eligibility documents. According to the California WIC Policy and Procedure Manual, WIC WISE Forms JOB AID section, eligibility documents provided by an applicant or a re-certifying client are not required to be retained by the local agency. The County has communicated this finding to CDPH/WIC and the risk it presents. At this time, the County is working with CDPH/WIC to address this finding. Specific Corrective Plan Procedures addressing Condition #1 Staff participate in a robust Quality Assurance (QA) plan which involves periodic file reviews and observations as documented in Solano County’s Continuous Quality Improvement (CQI) Monitoring Plan. Additionally, CDPH/WIC conducts a Program Monitoring Visit (PMV) every two years which includes a random record review of the agency’s compliance to eligibility policies. Solano County WIC program will continue to conduct the QA plan, and participate with the CDPH/WIC PMVs. Response to Condition #2 Solano County agrees with the finding. This use of the Self Declaration Statement (SDS) is a specific consideration in the QA plan. The WIC Supervisor was aware of the matter as it was discovered that both SDSs were missing from the family file as part of a regular QA review. The error was addressed with the employee shortly after the mistake occurred. Specific Corrective Plan Procedures addressing Condition #2 Staff participate in a Quality Assurance (QA) plan which involves periodic file reviews and observations as documented in Solano County’s Continuous Quality Improvement (CQI) Monitoring Plan. Additionally, CDPH/WIC conducts a Program Monitoring Visit (PMV) every two years which includes a random record review of the agency’s compliance to eligibility policies. Solano County WIC program will continue to conduct the QA plan, and participate with the CDPH/WIC PMVs. Responsible Individual(s): Christopher Husing, Senior Health Services Manager, Solano Public Health Anticipated Completion Date: April 1, 2025

Categories

Eligibility Material Weakness

Other Findings in this Audit

  • 551124 2024-002
    Material Weakness Repeat
  • 551125 2024-003
    Material Weakness Repeat
  • 551126 2024-002
    Material Weakness Repeat
  • 551127 2024-003
    Material Weakness Repeat
  • 551128 2024-004
    Material Weakness Repeat
  • 551129 2024-005
    Material Weakness Repeat
  • 551131 2024-007
    Material Weakness
  • 551132 2024-008
    Material Weakness
  • 551133 2024-009
    Material Weakness
  • 1127566 2024-002
    Material Weakness Repeat
  • 1127567 2024-003
    Material Weakness Repeat
  • 1127568 2024-002
    Material Weakness Repeat
  • 1127569 2024-003
    Material Weakness Repeat
  • 1127570 2024-004
    Material Weakness Repeat
  • 1127571 2024-005
    Material Weakness Repeat
  • 1127572 2024-006
    Material Weakness
  • 1127573 2024-007
    Material Weakness
  • 1127574 2024-008
    Material Weakness
  • 1127575 2024-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance for Needy Families $34.64M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $26.74M
93.778 Medical Assistance Program $25.49M
93.563 Child Support Services $8.21M
93.658 Foster Care Title IV-E $8.04M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $6.78M
93.659 Adoption Assistance $6.42M
14.871 Section 8 Housing Choice Vouchers $3.35M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $3.34M
93.498 Covid-19 Provider Relief Fund and American Rescue Plan (arp) Rural Distribution $1.85M
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.73M
93.493 Congressional Directives $959,528
93.268 Immunization Cooperative Agreements $837,626
93.090 Guardianship Assistance $767,628
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $765,610
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $746,426
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $708,692
16.575 Crime Victim Assistance $635,975
20.205 Highway Planning and Construction $628,045
93.958 Block Grants for Community Mental Health Services $506,140
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $424,659
16.606 State Criminal Alien Assistance Program $394,927
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $362,314
93.958 Covid-19 Block Grants for Community Mental Health Services $362,153
93.667 Social Services Block Grant $356,384
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $333,754
93.994 Maternal and Child Health Services Block Grant to the States $323,782
93.069 Public Health Emergency Preparedness $302,111
20.616 National Priority Safety Programs $294,731
93.052 National Family Caregiver Support, Title Iii, Part E $294,264
93.044 Covid-19 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $289,012
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $269,383
93.053 Nutrition Services Incentive Program $266,373
93.526 Grants for Capital Development in Health Centers $255,823
93.556 Marylee Allen Promoting Safe and Stable Families Program $236,441
93.889 National Bioterrorism Hospital Preparedness Program $196,468
14.879 Mainstream Vouchers $187,605
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $187,186
97.042 Emergency Management Performance Grants $158,071
14.896 Family Self-Sufficiency Program $155,586
17.278 Wioa Dislocated Worker Formula Grants $147,462
93.645 Stephanie Tubbs Jones Child Welfare Services Program $143,203
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $128,700
93.940 Hiv Prevention Activities Health Department Based $125,372
20.106 Covid-19 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $115,934
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $104,751
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $92,833
97.012 Boating Safety Financial Assistance $85,878
59.037 Small Business Development Centers $69,625
93.747 Elder Abuse Prevention Interventions Program $66,066
17.258 Wioa Adult Program $62,160
10.025 Plant and Animal Disease, Pest Control, and Animal Care $61,139
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $57,750
93.959 Block Grants for Prevention and Treatment of Substance Abuse $55,000
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $53,578
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $50,750
93.590 Community-Based Child Abuse Prevention Grants $38,567
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $38,494
93.043 Covid-19 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $36,060
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $30,142
93.917 Hiv Care Formula Grants $25,166
93.959 Covid-19 Block Grants for Prevention and Treatment of Substance Abuse $23,521
16.738 Edward Byrne Memorial Justice Assistance Grant Program $21,673
17.259 Wioa Youth Activities $11,867
93.527 Covid-19 Grants for New and Expanded Services Under the Health Center Program $11,337
16.U02 Safe Streets Crime Incentive $10,544
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $10,284
93.042 Covid-19 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $6,145
16.U04 Domestic Cannabis Eradication Suppression Program $5,477
93.603 Adoption and Legal Guardianship Incentive Payments Program $4,191
16.U03 Domestic Cannabis Eradication Suppression Program $3,184
97.067 Homeland Security Grant Program $247