Finding 565368 (2023-002)

Significant Deficiency
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2025-06-18
Audit: 359207
Auditor: Wipfli LLP

AI Summary

  • Core Issue: Several individuals received diapers despite not being income-eligible for the TANF program.
  • Impacted Requirements: The program requires strict eligibility verification, which is currently lacking.
  • Recommended Follow-Up: Implement a tracking system for diaper purchases and distributions to ensure compliance with eligibility criteria.

Finding Text

2023-002 – Eligibility Documentation Federal Program Information: Funding agency: US Department of Health and Human Services, passed through Michigan Department of Health and Human Services Title: Temporary Assistance for Needy Families AL number: 93.558 Award Numbers: E20234318-00, E20234318-00 Condition – Mid-Michigan Community Action Agency, Inc.'s operates a diaper bank program and utilizes other entities to distribute diapers to program eligible participants. During our test of eligibility, we noted several individuals that were not income-eligible for the program. Management of Mid-Michigan Community Action Agency, Inc. represented that in cases of individuals that are determined ineligible that the entities distributing the diapers will utilize diapers from other sources. However, Mid-Michigan Community Action Agency, Inc. was not able to substantiate the use of diapers from other sources. Criteria – The Temporary Assistance for Needy Families (TANF) program requires individuals receiving assistance to be eligible for the program. Cause – Mid-Michigan Community Action Agency, Inc. does not have a process in place to track the purchase and issuance of diapers purchased with TANF funds. Effect – A significant deficiency in internal control over eligibility exits due to the lack of documentation over the distribution of diapers to income eligible participants. Recommendation – We recommend management and those charged with governance evaluate the controls over this program to establish a mechanism that tracks the purchase and issuance of diapers to income-eligible participants. View of Responsible Officials – Management agrees with the assessment and has committed to a corrective action plan.

Corrective Action Plan

Finding 2023-002: Eligibility Documentation Management’s Response Mid Michigan CAA acknowledges the audit finding regarding the documentation of diaper distribution to income-eligible participants under the Temporary Assistance for Needy Families (TANF) program. We appreciate the opportunity to provide clarification and outline corrective actions. The Diaper Bank Program operated under the oversight of the Michigan Department of Health and Human Services (MDHHS), which conducted regular monitoring and did not identify any concerns related to eligibility or distribution practices during their reviews. In accordance with program requirements, all participating diaper banks were pre-existing programs with access to alternative funding sources. These sources were explicitly intended to support the distribution of diapers to households that did not meet TANF income eligibility criteria. While Mid Michigan CAA did not maintain centralized documentation of the specific funding source used for each distribution, it was understood and communicated to partner entities that TANF-funded diapers were to be reserved for eligible households only. To strengthen internal controls and ensure full compliance with TANF requirements, Mid Michigan CAA has implemented the following measures: 1. Development of a standardized tracking system to document only diapers distributed to each household using TANF funds. 2. Training for all partner entities on eligibility verification procedures and documentation requirements. 3. Periodic internal audits to verify compliance and ensure accurate recordkeeping. Contact Person Responsible for Corrective Action: Eva Rohlman, Outreach & Opportunities Director Anticipated Completion Date: 10/1/2024

Categories

Eligibility Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 565361 2023-001
    Material Weakness
  • 565362 2023-001
    Material Weakness
  • 565363 2023-001
    Material Weakness
  • 565364 2023-001
    Material Weakness
  • 565365 2023-001
    Material Weakness
  • 565366 2023-001
    Material Weakness
  • 565367 2023-001
    Material Weakness
  • 1141803 2023-001
    Material Weakness
  • 1141804 2023-001
    Material Weakness
  • 1141805 2023-001
    Material Weakness
  • 1141806 2023-001
    Material Weakness
  • 1141807 2023-001
    Material Weakness
  • 1141808 2023-001
    Material Weakness
  • 1141809 2023-001
    Material Weakness
  • 1141810 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
81.042 Weatherization Assistance for Low-Income Persons $2.24M
93.600 Head Start $2.20M
10.565 Commodity Supplemental Food Program $1.60M
93.569 Community Services Block Grant $1.53M
93.568 Low-Income Home Energy Assistance $1.08M
64.033 Va Supportive Services for Veteran Families Program $836,544
93.558 Temporary Assistance for Needy Families $768,327
10.569 Emergency Food Assistance Program (food Commodities) $578,780
14.231 Emergency Solutions Grant Program $424,333
93.499 Covid-19 Low Income Household Water Assistance Program $407,345
14.235 Supportive Housing Program $393,792
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $383,032
10.568 Commodity Supplemental Food Program $184,817
10.558 Child and Adult Care Food Program $151,220
21.023 Covid-19 Emergency Rental Assistance Program $129,965
14.169 Housing Counseling Assistance Program $67,900
64.033 Covid-19 Va Supportive Services for Veteran Families Program $62,819
14.267 Continuum of Care Program $55,831
97.024 Covid-19 Emergency Food and Shelter National Board Program $53,657
93.600 Covid-19 Head Start $52,403
14.231 Covid-19 Emergency Solutions Grant Program $43,757
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $20,000
14.239 Home Investment Partnerships Program $16,699
97.024 Emergency Food and Shelter National Board Program $16,230
14.871 Section 8 Housing Choice Vouchers $6,566
10.182 Local Food Purchase Assistance $3,984