Finding Text
2023-001 - Eligibility, Repeat Finding - see prior year finding 2022-001
Funding Agency: United States Department of Agriculture, Passed through the Michigan Department of Education
Title: Food Distribution Cluster
Assistance Listing Number: 10.565
Award Number: 220001006C
Award Period: October 1, 2022 through September 30, 2023
Questioned Costs: None
How Questioned Costs Were Computed: N/A
Criteria or Specific Requirement: A local agency certifies households as eligible to receive a CSFP food package by applying categorical and income eligibility criteria. Categorical eligibility requirements include elderly (persons at least 60 years of age) and women, infants, and children. Income eligibility requirements for elderly persons (which are Dickinson-Iron Community Services Agency's primary population of participants) must have income at or below 130 percent of the federal poverty level. The local agency certifies households eligible to receive CSFP assistance by applying the federal poverty guidelines to the household. The local agency is required to design and implement appropriate internal controls over compliance to prevent, or detect and correct noncompliance on a timely basis.
Condition: In our sample of 40 individuals tested for internal controls over compliance and eligibility compliance, one individual was found to be residing in a household that exceeded the federal poverty guidelines based on family size and income and was therefore not eligible to receive a CSFP food package. In addition, three individuals out of our sample of 40 did not have a signature from a Dickinson-Iron Community Services Agency employee to prove that proper review of the application took place. The households for which these individuals applied were eligible for services and the original applications had been entered into an electronic data base for tracking, but we were unable to prove that the applications had been reviewed.
Context: Dickinson-Iron Community Services Agency, much like many nonprofit organizations, experienced significant disruption and reorganization during the COVID-19 pandemic.
Cause: Due to turnover in staffing, Dickinson-Iron Community Services Agency failed to follow through on their corrective action plan for our finding in 2022. The Organization failed to design and operate internal control to effectively maintain original records of eligibility and to effectively ensure that eligibility was being determined properly at all sites.
Effect: When internal controls over compliance are ineffectively executed, there is a risk that ineligible individuals will be served.
Auditor's Recommendation: Wipfli recommends that Dickinson-Iron Community Services Agency implement a consistent application review process to ensure that ineligible individuals do not receive CSFP food packages.
View of Responsible Official: We agree with the finding and are committed to implementing corrective action.