Marquette CountyLocal Government

Finding 2024-002 Repeat of Finding 2023-002 Program Federal Assistance Listing and Title: 93.778 Medicaid Cluster, Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Wisconsin Department of Health Services Program Federal Assistance Listing and Title: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Wisconsin Department of Health Services State Program ID Number and Title: 437.3561/3681 CW Children and Families State Agency: Wisconsin Department of Children and Families State Program ID Number and Title: 435.560100 ADRC 435.000561/000681 Basic County Allocation State Agency: Wisconsin Department of Health Services Award Numbers: Unknown Criteria: The State Single Audit Guidelines (SSAG) require that local entities receiving State awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission of reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: The County does not have controls in place to ensure there is documentation of the approval and review of reports prior to submission. Of the reports tested for the current year single audit, 12 of the 13 reports did not have documentation of the review process prior to submittal as follows: 10 of 10 monthly GEARS reports and 1 of 1 WIMCR annual reports did not have documentation of approval, and 1 of 2 monthly SPARC reports did not have documentation of approval. The sample was not statistically valid. Cause: The County did not have internal control procedures in place requiring an independent person to document their review of the reports before submission and to ensure the reports were submitted timely. Effect: Reports could contain errors due to the lack of review and/or funding could be reduced as a result of not submitting reports by the due dates. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there is a process for documentation of proper review and approval over completeness and accuracy of reports are in place before submissions to state agencies are completed. Management Response: The County is reviewing and updating its internal controls to put processes in place to ensure that there is documentation of the review process prior to submittal of reports. The anticipated completion date is beginning with reports dated 1/1/2026 and later.

Finding 2024-004 Repeat of Finding 2023-004 Program Federal Assistance Listing and Title: 93.778 Medicaid Cluster, Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Wisconsin Department of Health Services State Program ID Number and Title: 437.3561/3681 CW Children and Families State Agency: Wisconsin Department of Children and Families State Program ID Numbers and Titles: 435.560100 ADRC 435.000561/000681 Basic County Allocation State Agency: Wisconsin Department of Health Services State Program ID Number and Title: 395.168 Specialized Transit County Operating Aids (Elderly & Disabled) State Agency: Wisconsin Department of Transportation State Program ID Number and Title: 435.000283 IMAA State Share State Agency: Wisconsin Department of Health Services Award Numbers: Unknown Criteria: 2 CRF 200.303 Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The State Single Audit Guidelines (SSAG) require that local entities receiving State awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations and program compliance requirements. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including appropriate review and approval of expenditures. Condition/Context: During our testing, we were unable to view approval for the following number of payroll expenditures in each program: • 93.778: 13 out of 20 expenditures tested. • 435.000561/000681, 437.3561/3681: 7 out of 40 expenditures tested. • 435.560100: 14 out of 20 expenditures tested. For programs 395.168 and 435.000283, these are carried over from the prior year as controls have not changed within the system. These samples were not statistically valid. Cause: While review controls are in place, the County's system does not currently allow access to view the documentation of approval of payroll expenses beyond 365 days. Effect: Record retention requirements are not currently being met, which prevents outside reviewers from verifying whether or not effective controls over payroll exist for transactions older than 365 days. Questioned Costs: None noted. Recommendation: The County should work with its software provider and IT personnel to enhance documentation retention surrounding payroll approval support.   Management Response: In response to Finding 2024-004 regarding Internal Control Over Financial Reporting, note that the County is aware that there is lack of controls over its year-end financial reporting process. The County will endeavor to evaluate the need to increase additional staff to meet the deficiencies noted in the finding. However, due to its size, the County does not feel it is cost-effective to hire the number of employees needed to complete these task in house at this point in time and will rely on an outside audit firm. Administration is aware the current payroll and financial system allows to only go back to view payroll approvals within one year.

Finding 2023-002 Program Federal Assistance Listing and Title: 93.778 Medicaid Cluster State ID Number and Title: 435.283 IMAA State Share Award Number: Unknown Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Wisconsin Department of Health Services State Agency: Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission of monthly reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: After the Human Services Manager left the County in June of 2023, the County did not replace the position with another individual to continue performing the control of reviewing GEARS reports prior to submission for reimbursement. Two of the three GEARS reports tested in each program were not reviewed prior to submission as required by the state. The sample was not statistically valid. Cause: The County did not have internal control procedures in place requiring an independent person to review the reports before submission and ensure the reports were accurately and timely submitted. Effect: Reports were not submitted and those that were submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes over completeness and accuracy of reports are in place before submissions to state agencies are completed. Management Response: Efforts to fill the Human Services Financial Manager position were being actively pursued during the vacancy. The position was re-filled January 29, 2024. Discussion about a backup plan should this position be vacant again are occurring between human services and county administration.

Finding 2023-004 Program Federal Assistance Listing and Title: 93.778 Medicaid Cluster State ID Numbers and Titles: 435.283 IMAA State Share 395.168 Elderly and Handicapped County Aids Award Numbers: Unknown Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Wisconsin Department of Health Services State Agencies: Wisconsin Department of Health Services Wisconsin Department of Transportation Criteria: 2 CRF 200.303 Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations and program compliance requirements. The State Single Audit Guidelines (SSAG) require that local entities receiving State awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations and program compliance requirements. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including appropriate review and approval of expenditures. Condition/Context: During our testing, we were unable to view approval for the following number of expenditures in each program: • 93.778: 4 out of 7 of the expenditures tested. • 395.168: 15 out of 40 of the expenditures tested. • 435.283: 3 out of 6 of the expenditures tested. These samples were not statistically valid. Cause: While review controls are in place, the County's system does not currently allow access to view the documentation of approval of payroll expenses beyond 365 days. Effect: Record retention requirements are not currently being met, which prevents outside reviewers from verifying whether or not effective controls over payroll exist for transactions older than 365 days. Questioned Costs: None noted. Recommendation: The County should work with its software provider and IT personnel to enhance documentation retention surrounding payroll approval support. Management Response: The County is aware that there is a lack of controls over its year-end financial reporting process. The County will endeavor to evaluate the need to increase additional staff to meet the deficiencies noted in the finding. However, because of its size, the County does not feel it is cost-effective to hire the number of employees needed to complete these tasks in-house at this point in time and will rely on an outside audit firm to review financial statements, disclosures and schedules. County administration and financial staff review the adjustments and reports prepared by the auditors to ensure the accuracy of the information.

#2019-002 ? Purchase of Services Contract (Prior Year Finding #2018-002) Federal CFDA Number and Title: 93.778 Medicaid Cluster Federal Grantor: U.S. Department of Health and Human Services Pass-through Award Number and Year: 39-810, 2019 Pass-through Entity: Wisconsin Department of Human Services Criteria: A portion of the reported expenditures for Medicaid Cluster line items on the Schedule of Expenditures of Federal Awards flows through the Children's Long-Term Support (CLTS) Waiver Program. Per the State of Wisconsin Department of Health Services (DHS) Audit Guide and the 2019 State and County Contract surrounding the CLTS Waiver Program, the County must provide assurance to DHS regarding certain requirements surrounding provider compliance with DHS training and minimum qualification requirements. DHS requires the County waiver agency (CWA) to ensure that CLTS Waiver Program service providers meet the applicable standards for allowable services of the CLTS Waiver Program to claim reimbursement. The CWA must provide assurance to DHS that each provider (1) is properly trained, licensed or credentialed to deliver authorized services and to maintain documentation that these requirements have been met and that (2) caregiver background checks are completed for each provider listed on the Individual Service Plan (ISP) for each CLTS Waiver Program client. In addition to the aforementioned requirements surrounding provider compliance, the CWA must also ensure that CLTS Waiver Program providers receiving more than $10,000 in funds throughout the contract period (calendar year) have a purchase of services contract that meets DHS standards. For each provider, the CWA must ensure that the purchase of services contract includes: (1) an established rate-setting methodology and (2) a process surrounding the collection of annual audit reports for each provider. Condition: During testing of service providers for a haphazardly selected sample of CLTS Waiver Program clients, it was noted that responsibility for the determination of provider eligibility, contracting, and audit report collection were being delegated to an outside vendor. The CWA did not perform procedures or monitoring activities to ensure that the vendor?s determinations were sufficient to satisfy DHS requirements. Furthermore, no contract or memorandum of understanding existed between the County and the vendor detailing the nature of these responsibilities. Cause: The County does not currently have a control process in place to provide assurance to DHS that mandated requirements surrounding provider compliance with DHS training and minimum qualification requirements are upheld. Although the County delegates this responsibility to an outside vendor, no monitoring of the vendor?s determinations or contracting is performed by the CWA. Effect: Providers could be selected to perform services for CLTS Waiver Program clients that failed background checks or are otherwise barred from receiving caregiver payments from Medicaid. Questioned Costs: None noted Context: Based on discussions with CLTS Waiver Program management at the County, the outside vendor is performing the required background and DHS qualification checks on behalf of the CWA. The outside vendor will alert program management if any providers selected by the CLTS client?s family fail their respective background checks or are found to be unsuitable for any reason(s). For 2020, a purchase of services contract was drafted and signed between the CWA and the outside vendor and monitoring of determinations is performed by the CWA. The sampling performed was not statistically valid. Recommendation: The County should draft a purchases of service contract between the outside vendor and itself that formally documents the responsibility placed on the vendor to perform provider eligibility checks. Monitoring on a sample basis should then be performed and documented surrounding the outside vendor?s conclusions on provider eligibility on an ongoing basis. Response: See corrective action plan.

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