FAC Explorer

Finding 971172 (2023-014)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-04-25
Audit: 304593
Organization: Charter County of Wayne, Michigan (MI)
Auditor: Plante & Moran PLLC

AI Summary

  • Core Issue: The County lacks adequate controls to ensure compliance with eligibility standards, as contractor employees are performing both intake and certification without county oversight.
  • Impacted Requirements: This finding represents a material weakness and noncompliance with federal regulations, specifically 2 CFR 200.501(g) and MI-WIC Policy regarding separation of duties.
  • Recommended Follow-up: Ensure that a county representative reviews all contractor eligibility determinations to maintain compliance and prevent future issues.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - 10.557, U.S. Department of Agriculture - WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Award Identification Number and Year - E20233245-00 and E20234077-00 Pass-through Entity - Michigan Department of Health and Human Services Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes; 2022-011 Criteria - Per 2 CFR 200.501(g), federal award compliance requirements normally do not pass through to contractors. However, the grant recipient is responsible for ensuring compliance for procurement transactions, which are structured such that the contractor is responsible for program compliance or the contractor’s records must be reviewed to determine program compliance. Condition - Controls in place were not adequate to ensure the County maintained responsibility for compliance with eligibility standards when eligibility determinations are made by the contractor. Questioned Costs - None Identification of How Questioned Costs Were Computed - Not applicable, as there are no questioned costs Context - During eligibility testing, we noted 31 out of 60 eligibility samples where employees of the contractor performed both the intake and the certification and review function, with no further review by a county representative. Cause and Effect - The County is subject to the MI-WIC Policy issued by the Michigan Department of Health and Human Services, which stresses the importance of maintaining appropriate separation of duties when performing the intake and certification of eligible program participants. While the County has designed its controls in conjunction with the MI-WIC Policy guidance, these controls are not adequate to ensure compliance with the Uniform Guidance, which requires the County have controls in place to ensure that a representative of the County performs a review of eligibility intake and certification performed by contractor employees. Recommendation - We recommend the County implement a process by which a county representative performs a review of contractor eligibility determinations. Views of Responsible Officials and Corrective Action Plan - Management has fully implemented a process, as of January 2024, by which a county representative performs a review of contractor eligibility determinations.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility Material Weakness

Other Findings in this Audit

  • 394712 2023-010
    Material Weakness
  • 394713 2023-011
    Significant Deficiency
  • 394714 2023-012
    Material Weakness
  • 394715 2023-012
    Material Weakness
  • 394716 2023-012
    Material Weakness
  • 394717 2023-012
    Material Weakness
  • 394718 2023-012
    Material Weakness
  • 394719 2023-012
    Material Weakness
  • 394720 2023-012
    Material Weakness
  • 394721 2023-012
    Material Weakness
  • 394722 2023-012
    Material Weakness
  • 394723 2023-012
    Material Weakness
  • 394724 2023-012
    Material Weakness
  • 394725 2023-012
    Material Weakness
  • 394726 2023-012
    Material Weakness
  • 394727 2023-012
    Material Weakness
  • 394728 2023-013
    Material Weakness
  • 394729 2023-014
    Material Weakness Repeat
  • 394730 2023-014
    Material Weakness Repeat
  • 394731 2023-015
    Material Weakness Repeat
  • 394732 2023-015
    Material Weakness Repeat
  • 394733 2023-015
    Material Weakness Repeat
  • 394734 2023-015
    Material Weakness Repeat
  • 394735 2023-015
    Material Weakness Repeat
  • 394736 2023-015
    Material Weakness Repeat
  • 394737 2023-015
    Material Weakness Repeat
  • 394738 2023-015
    Material Weakness Repeat
  • 394739 2023-016
    Significant Deficiency
  • 394740 2023-016
    Significant Deficiency
  • 394741 2023-016
    Significant Deficiency
  • 394742 2023-016
    Significant Deficiency
  • 394743 2023-016
    Significant Deficiency
  • 394744 2023-016
    Significant Deficiency
  • 394745 2023-016
    Significant Deficiency
  • 394746 2023-016
    Significant Deficiency
  • 394747 2023-017
    Significant Deficiency
  • 971154 2023-010
    Material Weakness
  • 971155 2023-011
    Significant Deficiency
  • 971156 2023-012
    Material Weakness
  • 971157 2023-012
    Material Weakness
  • 971158 2023-012
    Material Weakness
  • 971159 2023-012
    Material Weakness
  • 971160 2023-012
    Material Weakness
  • 971161 2023-012
    Material Weakness
  • 971162 2023-012
    Material Weakness
  • 971163 2023-012
    Material Weakness
  • 971164 2023-012
    Material Weakness
  • 971165 2023-012
    Material Weakness
  • 971166 2023-012
    Material Weakness
  • 971167 2023-012
    Material Weakness
  • 971168 2023-012
    Material Weakness
  • 971169 2023-012
    Material Weakness
  • 971170 2023-013
    Material Weakness
  • 971171 2023-014
    Material Weakness Repeat
  • 971173 2023-015
    Material Weakness Repeat
  • 971174 2023-015
    Material Weakness Repeat
  • 971175 2023-015
    Material Weakness Repeat
  • 971176 2023-015
    Material Weakness Repeat
  • 971177 2023-015
    Material Weakness Repeat
  • 971178 2023-015
    Material Weakness Repeat
  • 971179 2023-015
    Material Weakness Repeat
  • 971180 2023-015
    Material Weakness Repeat
  • 971181 2023-016
    Significant Deficiency
  • 971182 2023-016
    Significant Deficiency
  • 971183 2023-016
    Significant Deficiency
  • 971184 2023-016
    Significant Deficiency
  • 971185 2023-016
    Significant Deficiency
  • 971186 2023-016
    Significant Deficiency
  • 971187 2023-016
    Significant Deficiency
  • 971188 2023-016
    Significant Deficiency
  • 971189 2023-017
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.023 Covid-19 - Emergency Rental Assistance Program $13.81M
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $2.77M
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $1.81M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.42M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.41M
14.231 Covid-19 - Emergency Solutions Grant Program $1.14M
66.469 Great Lakes Program $1.01M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $957,000
93.137 Covid-19 - Community Programs to Improve Minority Health Grant Program $947,779
14.228 Covid-19 - Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $862,345
93.268 Covid-19 - Immunization Cooperative Agreements $843,398
16.575 Crime Victim Assistance $834,082
93.658 Foster Care_title IV-E $741,000
93.053 Nutrition Services Incentive Program $654,605
93.563 Child Support Enforcement $648,004
14.218 Community Development Block Grants/entitlement Grants $508,760
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $503,426
93.224 Covid-19 - Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $374,516
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $332,125
93.268 Immunization Cooperative Agreements $321,880
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $306,867
16.588 Violence Against Women Formula Grants $275,834
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $261,069
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $239,291
14.231 Emergency Solutions Grant Program $235,226
93.767 Children's Health Insurance Program $234,037
16.606 State Criminal Alien Assistance Program $184,035
93.889 National Bioterrorism Hospital Preparedness Program $145,701
93.940 Hiv Prevention Activities_health Department Based $144,819
20.205 Highway Planning and Construction $140,613
16.585 Drug Court Discretionary Grant Program $131,223
97.012 Boating Safety Financial Assistance $129,200
16.710 Public Safety Partnership and Community Policing Grants $128,323
97.067 Homeland Security Grant Program $80,844
97.042 Emergency Management Performance Grants $62,952
93.069 Public Health Emergency Preparedness $59,381
16.738 Edward Byrne Memorial Justice Assistance Grant Program $53,010
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $49,496
14.239 Covid-19 - Home Investment Partnerships Program $32,655
16.833 National Sexual Assault Kit Initiative $27,915
66.818 Brownfields Assessment and Cleanup Cooperative Agreements $26,720
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $24,242
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $23,997
14.239 Home Investment Partnerships Program $21,419
93.472 Title IV-E Prevention and Family Services and Programs (a) $19,458
16.554 National Criminal History Improvement Program (nchip) $18,695
93.778 Medical Assistance Program $16,670
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $14,383
93.870 Covid-19 - Maternal, Infant and Early Childhood Home Visiting Grant $9,907
95.001 High Intensity Drug Trafficking Areas Program $8,232
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $7,764
93.994 Maternal and Child Health Services Block Grant to the States $239
66.468 Capitalization Grants for Drinking Water State Revolving Funds $231