Finding 980654 (2023-001)

Material Weakness
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2024-06-28
Audit: 310975
Organization: Genesee County, Michigan (MI)

AI Summary

  • Core Issue: There is a lack of independent review for eligibility determinations in the WIC and Food Distribution programs, which could lead to ineligible participants receiving benefits.
  • Impacted Requirements: The County must ensure eligibility criteria are met as per grant agreements and federal regulations, specifically 7 CFR sections related to both programs.
  • Recommended Follow-Up: Implement a two-step verification process for eligibility checks, involving a second employee to confirm eligibility after initial entry.

Finding Text

2023 001 Assistance Listing, Federal Agency, and Program Name ALN 10.557, U.S. Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) ALN 10.565, U.S. Department of Agriculture, Food Distribution Cluster Federal Award Identification Number and Year E20233413 00 (2023) and E20232456 00 (2023) (WIC) N/A (Food Distribution) Pass through Entity Michigan Department of Health and Human Services (WIC) Michigan Department of Education (Food Distribution) Finding Type Material weakness Repeat Finding No Criteria Per the grant agreement, the County is required to initially certify recipients to ensure eligibility criteria are met for the WIC program and benefits are provided to eligibile participants as defined by 7 CFR sections 246.7(c), (d), (e), (g), and (l). Per the grant agreement, the County is required to ensure eligibility criteria are met for the food distribution program to confine distribution of United States Department of Agriculture (USDA) foods received from the state agency to recipients determined to be eligible in accordance with instructions issued by the state agency and the 7 CFR Part 247, 250 and Food and Nutrition Service Food Package instructions for the Commodity Supplement Food Program. Condition During testing, it was noted that although there was a process in place to review eligibility criteria received by both programs, there was not an independent review or control to ensure eligibility was accurate. Questioned Costs None Identification of How Questioned Costs Were Computed Not applicable Context From October 1, 2022 through September 30, 2023, all new participants requesting participation in the programs are required to provide eligibility criteria to be evaluated by the County for eligibility determination. Upon receiving this information, the County has one individual reviewing and entering the eligibility criteria into the system for both programs and determining eligibility. Cause and Effect There was no control in place to check eligibility after initial entry and recording of eligibility information within the program systems. Although no ineligible participants were discovered through testing performed, the lack of controls could result in a possibility of participants receiving benefits who are ineligible. Reference Number Finding Recommendation We recommend that an internal control be put in place to ensure that there is a subsequent check of eligibility information and determinations made after the initial entry and recording of eligibility information. Views of Responsible Officials and Corrective Action Plan WIC: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review. Food Distribution Cluster: After the initial review and input of participant applications into the system, a new procedure will be introduced prior to distribution. Each client will undergo two verifications. The first verification will involve an employee verifying the client's information both manually against eligibility guidelines and electronically with program software. If the information is found to meet eligibility, a document will be signed and provided to the participant. The second verification will involve the client giving the signed documents to a second employee, who will also provide confirmation of eligibility and approve distribution.

Categories

Eligibility Material Weakness

Other Findings in this Audit

  • 404210 2023-001
    Material Weakness
  • 404211 2023-001
    Material Weakness
  • 404212 2023-001
    Material Weakness
  • 404213 2023-001
    Significant Deficiency
  • 404214 2023-002
    Significant Deficiency
  • 404215 2023-002
    Significant Deficiency
  • 404216 2023-002
    Significant Deficiency
  • 404217 2023-003
    Material Weakness Repeat
  • 404218 2023-003
    Material Weakness Repeat
  • 404219 2023-003
    Material Weakness Repeat
  • 980652 2023-001
    Material Weakness
  • 980653 2023-001
    Material Weakness
  • 980655 2023-001
    Significant Deficiency
  • 980656 2023-002
    Significant Deficiency
  • 980657 2023-002
    Significant Deficiency
  • 980658 2023-002
    Significant Deficiency
  • 980659 2023-003
    Material Weakness Repeat
  • 980660 2023-003
    Material Weakness Repeat
  • 980661 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.023 Covid-19 - Emergency Rental Assistance Program $7.15M
10.569 Emergency Food Assistance Program (food Commodities) $2.59M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $2.10M
93.563 Child Support Enforcement $1.71M
93.569 Community Services Block Grant $1.17M
93.568 Low-Income Home Energy Assistance $1.14M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.09M
10.565 Commodity Supplemental Food Program $1.03M
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $902,236
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $671,959
14.231 Covid-19 - Emergency Solutions Grant Program $666,218
14.239 Home Investment Partnerships Program $597,425
93.926 Healthy Start Initiative $493,308
93.053 Nutrition Services Incentive Program $484,633
10.558 Child and Adult Care Food Program $439,271
81.042 Weatherization Assistance for Low-Income Persons $356,884
93.268 Covid-19 - Immunization Cooperative Agreements $313,687
16.575 Crime Victim Assistance $273,466
16.588 Violence Against Women Formula Grants $269,749
16.753 Congressionally Recommended Awards $263,033
14.218 Covid-19 - Community Development Block Grants/entitlement Grants $257,721
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $247,408
10.568 Emergency Food Assistance Program (administrative Costs) $211,728
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $201,544
93.268 Immunization Cooperative Agreements $177,031
93.658 Foster Care_title IV-E $153,071
16.738 Edward Byrne Memorial Justice Assistance Grant Program $149,890
93.994 Maternal and Child Health Services Block Grant to the States $148,722
14.231 Emergency Solutions Grant Program $147,142
93.600 Head Start $128,205
16.833 National Sexual Assault Kit Initiative $112,018
16.585 Drug Court Discretionary Grant Program $105,346
20.505 Metropolitan Transportation Planning and State and Non-Metropolitan Planning and Research $103,011
93.889 National Bioterrorism Hospital Preparedness Program $91,274
17.268 H-1b Job Training Grants $74,419
10.555 National School Lunch Program $64,137
93.940 Hiv Prevention Activities_health Department Based $62,322
97.024 Emergency Food and Shelter National Board Program $61,664
93.136 Injury Prevention and Control Research and State and Community Based Programs $56,891
93.217 Family Planning_services $54,263
21.032 Local Assistance and Tribal Consistency Fund $50,000
93.069 Public Health Emergency Preparedness $36,815
97.042 Emergency Management Performance Grants $36,412
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $32,308
93.558 Temporary Assistance for Needy Families $27,814
14.218 Community Development Block Grants/entitlement Grants $26,420
97.067 Homeland Security Grant Program $25,174
97.012 Boating Safety Financial Assistance $24,700
93.354 Covid-19 - Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $24,064
45.025 Promotion of the Arts_partnership Agreements $20,000
16.606 State Criminal Alien Assistance Program $16,451
16.034 Covid-19 - Coronavirus Emergency Supplemental Funding Program $14,382
93.597 Grants to States for Access and Visitation Programs $14,155
66.468 Capitalization Grants for Drinking Water State Revolving Funds $13,625
10.559 Summer Food Service Program for Children $8,652
93.778 Medical Assistance Program $4,555
20.205 Highway Planning and Construction $927