Cochise County

The County did not perform eligibility certification requirements, resulting in an increased risk of program participants receiving benefits they are not eligible to receive Assistance Listings number(s) and name(s): 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number(s) and year(s): CTR067930 October 1, 2023 through September 30, 2028 Federal agency: U.S. Department of Agriculture Pass-through grantor(s): Arizona Department of Health Services Compliance requirement(s): Eligibility Questioned costs: Unknown Condition Contrary to federal regulations and State policies, the County’s Health and Social Services Department (Department) issued program benefits without requiring each program participant to complete and sign a rights and obligations form during the eligibility certification process agreeing to provide current and truthful information, abide by program rules, and not share WIC benefits cards or other benefits. Specifically, for 17 of 60 participants tested, the Department did not require the participants to complete and sign a rights and obligations form for 9 participants’ initial certifications and 8 participants’ recertification for ongoing benefits. In addition, for 5 of 60 participants tested, the Department did not properly separate duties and allowed the same employee to determine eligibility and issue benefits to participants. Further, we found that 2 of 13 WIC employees responsible for determining a participant’s eligibility did not complete mandatory annual training. Effect The Department’s not requiring program participants to acknowledge their rights and obligations increases the risk of participants providing inaccurate information required for eligibility determinations, such as erroneous residency and income data that could allow program participants to receive benefits they are not eligible to receive. Further, there is an increased risk of misuse of program benefits received as the participants may not be aware of the program’s rules and could allow others to use their WIC benefits cards or inappropriately sell, trade, or give away benefits received, such as food, formula, or breast pumps. Finally, the Department’s not properly separating duties or providing mandatory annual training increases the risk of fraud and awarding benefits to ineligible participants. Cause Department management reported that there was misdirection by the previous WIC director who communicated to staff that only the participation consent form, not the rights and obligations form, was required to be signed. In addition, Department management reported that for part of the fiscal year when 2 employees were updating a participant’s information at the same time, the employees did not properly save who completed a participant’s eligibility determination and who approved it in the State’s eligibility system. Further, the Department did not perform periodic monitoring to ensure (1) Department clinic site staff required participants to sign the rights and obligations form prior to issuing benefits and that the forms were maintained in the State’s eligibility system, (2) separation of duties was properly documented in the State’s eligibility system, or (3) WIC employees responsible for determining a participant’s eligibility completed mandatory annual training. Criteria Federal regulation and State policies require participants to sign a rights and obligations statement as part of the eligibility-certification process (7 CFR §246.7[i][10]). Specifically, State eligibility-certification policies require the Department’s staff who are responsible for the eligibility-certification process to inform participants of their rights and obligations prior to issuing benefits during the participant’s initial certification and recertifications for ongoing benefits. Also, the participants must complete and sign the form acknowledging their rights and obligations, including: Providing the most current and truthful information that WIC staff may verify. Following the WIC program’s rules to avoid being prosecuted, disqualified, and/or asked to repay the program. Allowing only the approved authorized recipient or proxy to use the WIC benefits card and reporting lost or stolen WIC benefits cards. Being honest and not selling, trading, or giving away WIC benefits cards, food, formula, or breast pumps, and acknowledging that doing so will disqualify the recipient from benefits. In addition, policies and procedures over WIC certifications completed at a local agency should prohibit 1 employee from determining eligibility for all certification criteria and issuing benefits to participants or provide effective alternative policies and procedures when separation of duties is not possible (7 CFR §246.4[a][27][iii]). Further, State pass-through entity grant award requires the Department to provide training to all WIC employees responsible for determining a participant’s eligibility. Finally, federal guidelines require establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the Department Follow the State’s eligibility certification policies that require program participants to complete and sign a rights and obligations form prior to the Department issuing benefits during initial certifications and recertifications for ongoing benefits. Train Department staff, who are responsible for the eligibility certification process, as required by the State pass-through, regarding the following requirements: Participants must be informed of their rights and obligations prior to issuing benefits during the participant’s initial certification and recertifications for ongoing benefits. Participants must sign the rights and obligations form during the eligibility certification process agreeing to provide current and truthful information, abide by program rules, and not share WIC benefits cards or other benefits. Department staff must maintain the forms in its eligibility system. Separate job responsibilities in policies and procedures to prohibit 1 employee from determining eligibility for all certification criteria and issuing benefits to participants or provide effective alternative policies and procedures when separation of duties is not possible. Perform periodic monitoring at its clinic sites to ensure: Department clinic site staff require participants to sign the rights and obligations form prior to issuing benefits and that the forms are maintained in the State’s eligibility system. Separation of duties is properly documented in the State’s eligibility system. WIC employees responsible for determining a participant’s eligibility complete mandatory training. This finding is similar to prior-year finding 2024-101 and was initially reported in fiscal year 2024. Views of responsible officials County management concurs with this finding. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials regarding these recommendations. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award numbers and years: CTR040363, October 1, 2018 through September 30, 2023; CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Department of Agriculture Pass-through grantor: Arizona Department of Health Services Compliance requirement: Eligibility Questioned costs: Unknown1

Condition—Contrary to federal regulations and State policies, the County’s Health and Social Services Department (Department) issued program benefits without requiring each program participant to complete and sign a rights and obligations form during the eligibility certification process agreeing to provide current and truthful information, abide by program rules, and not share WIC benefits cards or other benefits. Specifically, for 15 of 62 participants tested, the Department did not require the participants to complete and sign a rights and obligations form for 6 participants’ initial certifications and 9 participants’ recertifications for ongoing benefits.

Effect—The Department’s not requiring program participants to acknowledge their rights and obligations increases the risk of participants providing inaccurate information required for eligibility determinations, such as erroneous residency and income data that could allow program participants to receive benefits they are not eligible to receive.1 Further, there is an increased risk of misuse of program benefits received as the participants may not be aware of the program’s rules and could allow others to use their WIC benefits cards or sell, trade, or give away benefits received, such as food, formula, or breast pumps.

Cause—Department management reported that State policies were not always followed because the program is administered at small clinic sites throughout the County, and Department staff who are responsible for ensuring each program participant complete and sign a rights and obligations form were busy and forgot to have each program participant do so. Further, the Department did not perform periodic monitoring to ensure Department clinic site staff had required participants to sign the rights and obligations form prior to issuing benefits and that the forms were maintained in its eligibility system.

Criteria—Federal regulation and State policies require participants to sign a rights and obligations statement as part of the eligibility certification process (7 CFR 246.7[i][10]).2 Specifically, State eligibility certification policies require the Department’s staff who are responsible for the eligibility certification process to inform participants of their rights and obligations prior to issuing benefits during the participant’s initial certification and recertifications for ongoing benefits.

Also, the participants must complete and sign the form acknowledging their rights and obligations, including:

• Providing the most current and truthful information that WIC staff may verify. • Following the rules of the WIC program to avoid being prosecuted, disqualified, and/or asked to repay the program. • Allowing only the approved authorized recipient or proxy to use the WIC benefits card and reporting lost or stolen WIC benefits cards.1 • Being honest and not selling, trading, or giving away WIC benefits cards, food, formula, or breast pumps, and acknowledging that doing so will disqualify the recipient from benefits.

Further, federal guidelines require establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303).

Recommendations to the Department—

1. Follow the State’s eligibility certification policies that require program participants to complete and sign a rights and obligations form prior to the Department issuing benefits during initial certifications and recertifications for ongoing benefits. 2. Train Department staff who are responsible for the eligibility certification process regarding the following requirements: a. Participants must be informed of their rights and obligations prior to issuing benefits during the participant’s initial certification and recertifications for ongoing benefits. b. Participants must sign the rights and obligations form during the eligibility certification process agreeing to provide current and truthful information, abide by program rules, and not share WIC benefits cards or other benefits. c. Department staff must maintain the forms in its eligibility system. 3. Perform periodic monitoring at its clinic sites to ensure Department staff who are responsible for the eligibility certification process are performing all steps.

The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.

1 WIC recipients receive WIC benefits cards to use at designated vendors, such as a grocery store, that are preloaded with eligible food packages. A food package contains items by description and provides only specific quantities for fruits and vegetables. For example, 2 dozen eggs, 32 ounces of yogurt, 1 pound of cheese, etc. The recipient can purchase only the eligible items and specific quantities outlined in their designated food package. Unused benefits expire at the end of the month. For the errors identified, auditors were unable to determine the potential questioned cost as there is not a specific amount designated for each food package awarded to the recipients. The vendors who supplied food to the recipient bill the Arizona Department of Health Services for the benefits provided. 2 Arizona Department of Health Services. (2024). Arizona WIC Program Policy and Procedure Manual Chapter 2, Section H. Retrieved 4/30/2025 from https://www.azdhs.gov/documents/prevention/azwic/manuals/policy/chapter-02-certification.pdf?v=20240221