Audit 2802

2022 – 003 Procurement and Suspension and Debarment Federal Agency: U.S. Department Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324, 2 CFR 180.220, and 2 CFR 200.320,) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred (covered transactions over $25,000). These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Procurement methods used must be appropriate based on the dollar amount and conditions specified. Condition: Procurement methods for certain federal award purchases were not adequately documented or appropriately selected in accordance with the County’s procurement policy. In addition, the County did not maintain records the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: Unknown Context: 3 of 6 tested for procurement documentation and 5 of 5 tested for suspension and debarment documentation. Cause: With new federal funding opportunities due to the pandemic, and new guidance related to those grants, proper documentation was not retained. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: This is a repeat finding. Prior year finding numbers were 2021-004 and 2021-005. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure report filed during the year did not accurately report project details, including amounts expended and subrecipient entity types as contractors, beneficiaries, or subrecipients. In addition, there is no formal documentation of the review being completed by the County Administrator in accordance with the County’s internal control procedures. Questioned costs: None Context: The County incorrectly reported current projects and expenditures in 3 of 3 reports tested. Cause: Subaward and subrecipient types were not clearly distinguished. Revenue replacement reported was based on the full $10,000,000 lost revenue election, and not amounts of the revenue replacement used for expenses incurred through the reporting date. These details were inaccurately reported due to unclear instructions. There was no documentation of review and approval by a County Administrator. Effect: Noncompliance with reporting requirements. Repeat Finding: No Recommendation: We recommend the County strengthen its review procedures over reports and ensure the review is documented. The reports should include project expenditures incurred during the period and all applicable data elements. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure transactions for costs recorded for the end of the period of performance were not incurred after the period of performance for Federal awards. Additionally, manual journal entries should be supported by documentation for transactions that occurred during the period of performance. Condition: The County allocated costs to federal awards after the end of the period of performance. Documentation for manual adjusting journal entries was not maintained to ascertain transactions occurred during the period of performance. Questioned costs: $519,076 Context: 4 of 20 transactions tested were incurred after the period of performance end date. All 36 manual journal entries recorded to the programs did not have supporting documentation available. Cause: Costs were inadvertently claimed that fell outside the period of performance. Support for the accounting records could not be provided for the manual adjusting entries. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: No Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Supporting accounting records for manual adjusting journal entries should be maintained to support transactions incurred, with a documented approval process. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the draw down request are supported by documentation of expenditures that been incurred. Additionally, the time between drawing and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant cash draw request. The time between drawing and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval by an individual other than the preparer was not retained. Questioned costs: $198,122 Context: 5 of 5 cash draw down requests tested did not have supporting documentation of the exact amount drawn down maintained. Cause: Support for the draw down request could not be provided over the individual cash draw down request as it was not retained. Adjustments made to the project accounting records after the cash draw request were made caused the County to receive more funds than expenses incurred. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the draw request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the quarterly financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the quarterly financial reporting accounting records were not maintained. There was in instance in which the accounting records did not agree to the grant reconciliation submitted with the grant close-out package. Questioned costs: None Context: 3 of 4 quarterly financial reports tested did not have supporting documentation retained. 1 of 2 financial close out reports tested had accounting records that did not agree to the amounts reported. Cause: Support for the quarterly financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the quarterly financial reporting and grant close-out reports and documentation be retained. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 008 Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Number: 21-274038 Award Period: July 1, 2021 through September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include that participant file documentation and applications be reviewed for eligibility and this review should be documented. Condition: Participant files documents and application was reviewed by the intake coordinator for eligibility requirements but this review was not documented. Questioned costs: None Context: 1 of 60 tested did not have the application that was documented as reviewed by the intake coordinator. Cause: Management oversight. Effect: Lack of proper review over eligibility requirements could lead to ineligible participants receiving benefits. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of participant applications. A review process over the eligibility requirements should occur and be documented, to ensure eligibility requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure transactions for costs recorded for the end of the period of performance were not incurred after the period of performance for Federal awards. Additionally, manual journal entries should be supported by documentation for transactions that occurred during the period of performance. Condition: The County allocated costs to federal awards after the end of the period of performance. Documentation for manual adjusting journal entries was not maintained to ascertain transactions occurred during the period of performance. Questioned costs: $519,076 Context: 4 of 20 transactions tested were incurred after the period of performance end date. All 36 manual journal entries recorded to the programs did not have supporting documentation available. Cause: Costs were inadvertently claimed that fell outside the period of performance. Support for the accounting records could not be provided for the manual adjusting entries. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: No Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Supporting accounting records for manual adjusting journal entries should be maintained to support transactions incurred, with a documented approval process. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the draw down request are supported by documentation of expenditures that been incurred. Additionally, the time between drawing and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant cash draw request. The time between drawing and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval by an individual other than the preparer was not retained. Questioned costs: $198,122 Context: 5 of 5 cash draw down requests tested did not have supporting documentation of the exact amount drawn down maintained. Cause: Support for the draw down request could not be provided over the individual cash draw down request as it was not retained. Adjustments made to the project accounting records after the cash draw request were made caused the County to receive more funds than expenses incurred. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the draw request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the quarterly financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the quarterly financial reporting accounting records were not maintained. There was in instance in which the accounting records did not agree to the grant reconciliation submitted with the grant close-out package. Questioned costs: None Context: 3 of 4 quarterly financial reports tested did not have supporting documentation retained. 1 of 2 financial close out reports tested had accounting records that did not agree to the amounts reported. Cause: Support for the quarterly financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the quarterly financial reporting and grant close-out reports and documentation be retained. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 008 Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Number: 21-274038 Award Period: July 1, 2021 through September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include that participant file documentation and applications be reviewed for eligibility and this review should be documented. Condition: Participant files documents and application was reviewed by the intake coordinator for eligibility requirements but this review was not documented. Questioned costs: None Context: 1 of 60 tested did not have the application that was documented as reviewed by the intake coordinator. Cause: Management oversight. Effect: Lack of proper review over eligibility requirements could lead to ineligible participants receiving benefits. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of participant applications. A review process over the eligibility requirements should occur and be documented, to ensure eligibility requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure transactions for costs recorded for the end of the period of performance were not incurred after the period of performance for Federal awards. Additionally, manual journal entries should be supported by documentation for transactions that occurred during the period of performance. Condition: The County allocated costs to federal awards after the end of the period of performance. Documentation for manual adjusting journal entries was not maintained to ascertain transactions occurred during the period of performance. Questioned costs: $519,076 Context: 4 of 20 transactions tested were incurred after the period of performance end date. All 36 manual journal entries recorded to the programs did not have supporting documentation available. Cause: Costs were inadvertently claimed that fell outside the period of performance. Support for the accounting records could not be provided for the manual adjusting entries. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: No Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Supporting accounting records for manual adjusting journal entries should be maintained to support transactions incurred, with a documented approval process. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the draw down request are supported by documentation of expenditures that been incurred. Additionally, the time between drawing and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant cash draw request. The time between drawing and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval by an individual other than the preparer was not retained. Questioned costs: $198,122 Context: 5 of 5 cash draw down requests tested did not have supporting documentation of the exact amount drawn down maintained. Cause: Support for the draw down request could not be provided over the individual cash draw down request as it was not retained. Adjustments made to the project accounting records after the cash draw request were made caused the County to receive more funds than expenses incurred. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the draw request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the quarterly financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the quarterly financial reporting accounting records were not maintained. There was in instance in which the accounting records did not agree to the grant reconciliation submitted with the grant close-out package. Questioned costs: None Context: 3 of 4 quarterly financial reports tested did not have supporting documentation retained. 1 of 2 financial close out reports tested had accounting records that did not agree to the amounts reported. Cause: Support for the quarterly financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the quarterly financial reporting and grant close-out reports and documentation be retained. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 008 Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Number: 21-274038 Award Period: July 1, 2021 through September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include that participant file documentation and applications be reviewed for eligibility and this review should be documented. Condition: Participant files documents and application was reviewed by the intake coordinator for eligibility requirements but this review was not documented. Questioned costs: None Context: 1 of 60 tested did not have the application that was documented as reviewed by the intake coordinator. Cause: Management oversight. Effect: Lack of proper review over eligibility requirements could lead to ineligible participants receiving benefits. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of participant applications. A review process over the eligibility requirements should occur and be documented, to ensure eligibility requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 003 Procurement and Suspension and Debarment Federal Agency: U.S. Department Treasury Federal Program Name: Coronavirus State & Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324, 2 CFR 180.220, and 2 CFR 200.320,) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred (covered transactions over $25,000). These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Procurement methods used must be appropriate based on the dollar amount and conditions specified. Condition: Procurement methods for certain federal award purchases were not adequately documented or appropriately selected in accordance with the County’s procurement policy. In addition, the County did not maintain records the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: Unknown Context: 3 of 6 tested for procurement documentation and 5 of 5 tested for suspension and debarment documentation. Cause: With new federal funding opportunities due to the pandemic, and new guidance related to those grants, proper documentation was not retained. Effect: May result in a disallowed cost if grant requirements are not followed. Repeat Finding: This is a repeat finding. Prior year finding numbers were 2021-004 and 2021-005. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 004 Reporting Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3738 11/30/2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the expenditure report filed during the year did not accurately report project details, including amounts expended and subrecipient entity types as contractors, beneficiaries, or subrecipients. In addition, there is no formal documentation of the review being completed by the County Administrator in accordance with the County’s internal control procedures. Questioned costs: None Context: The County incorrectly reported current projects and expenditures in 3 of 3 reports tested. Cause: Subaward and subrecipient types were not clearly distinguished. Revenue replacement reported was based on the full $10,000,000 lost revenue election, and not amounts of the revenue replacement used for expenses incurred through the reporting date. These details were inaccurately reported due to unclear instructions. There was no documentation of review and approval by a County Administrator. Effect: Noncompliance with reporting requirements. Repeat Finding: No Recommendation: We recommend the County strengthen its review procedures over reports and ensure the review is documented. The reports should include project expenditures incurred during the period and all applicable data elements. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure transactions for costs recorded for the end of the period of performance were not incurred after the period of performance for Federal awards. Additionally, manual journal entries should be supported by documentation for transactions that occurred during the period of performance. Condition: The County allocated costs to federal awards after the end of the period of performance. Documentation for manual adjusting journal entries was not maintained to ascertain transactions occurred during the period of performance. Questioned costs: $519,076 Context: 4 of 20 transactions tested were incurred after the period of performance end date. All 36 manual journal entries recorded to the programs did not have supporting documentation available. Cause: Costs were inadvertently claimed that fell outside the period of performance. Support for the accounting records could not be provided for the manual adjusting entries. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: No Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Supporting accounting records for manual adjusting journal entries should be maintained to support transactions incurred, with a documented approval process. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the draw down request are supported by documentation of expenditures that been incurred. Additionally, the time between drawing and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant cash draw request. The time between drawing and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval by an individual other than the preparer was not retained. Questioned costs: $198,122 Context: 5 of 5 cash draw down requests tested did not have supporting documentation of the exact amount drawn down maintained. Cause: Support for the draw down request could not be provided over the individual cash draw down request as it was not retained. Adjustments made to the project accounting records after the cash draw request were made caused the County to receive more funds than expenses incurred. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the draw request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the quarterly financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the quarterly financial reporting accounting records were not maintained. There was in instance in which the accounting records did not agree to the grant reconciliation submitted with the grant close-out package. Questioned costs: None Context: 3 of 4 quarterly financial reports tested did not have supporting documentation retained. 1 of 2 financial close out reports tested had accounting records that did not agree to the amounts reported. Cause: Support for the quarterly financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the quarterly financial reporting and grant close-out reports and documentation be retained. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 008 Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Number: 21-274038 Award Period: July 1, 2021 through September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include that participant file documentation and applications be reviewed for eligibility and this review should be documented. Condition: Participant files documents and application was reviewed by the intake coordinator for eligibility requirements but this review was not documented. Questioned costs: None Context: 1 of 60 tested did not have the application that was documented as reviewed by the intake coordinator. Cause: Management oversight. Effect: Lack of proper review over eligibility requirements could lead to ineligible participants receiving benefits. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of participant applications. A review process over the eligibility requirements should occur and be documented, to ensure eligibility requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure transactions for costs recorded for the end of the period of performance were not incurred after the period of performance for Federal awards. Additionally, manual journal entries should be supported by documentation for transactions that occurred during the period of performance. Condition: The County allocated costs to federal awards after the end of the period of performance. Documentation for manual adjusting journal entries was not maintained to ascertain transactions occurred during the period of performance. Questioned costs: $519,076 Context: 4 of 20 transactions tested were incurred after the period of performance end date. All 36 manual journal entries recorded to the programs did not have supporting documentation available. Cause: Costs were inadvertently claimed that fell outside the period of performance. Support for the accounting records could not be provided for the manual adjusting entries. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: No Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Supporting accounting records for manual adjusting journal entries should be maintained to support transactions incurred, with a documented approval process. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the draw down request are supported by documentation of expenditures that been incurred. Additionally, the time between drawing and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant cash draw request. The time between drawing and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval by an individual other than the preparer was not retained. Questioned costs: $198,122 Context: 5 of 5 cash draw down requests tested did not have supporting documentation of the exact amount drawn down maintained. Cause: Support for the draw down request could not be provided over the individual cash draw down request as it was not retained. Adjustments made to the project accounting records after the cash draw request were made caused the County to receive more funds than expenses incurred. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the draw request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the quarterly financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the quarterly financial reporting accounting records were not maintained. There was in instance in which the accounting records did not agree to the grant reconciliation submitted with the grant close-out package. Questioned costs: None Context: 3 of 4 quarterly financial reports tested did not have supporting documentation retained. 1 of 2 financial close out reports tested had accounting records that did not agree to the amounts reported. Cause: Support for the quarterly financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the quarterly financial reporting and grant close-out reports and documentation be retained. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 008 Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Number: 21-274038 Award Period: July 1, 2021 through September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include that participant file documentation and applications be reviewed for eligibility and this review should be documented. Condition: Participant files documents and application was reviewed by the intake coordinator for eligibility requirements but this review was not documented. Questioned costs: None Context: 1 of 60 tested did not have the application that was documented as reviewed by the intake coordinator. Cause: Management oversight. Effect: Lack of proper review over eligibility requirements could lead to ineligible participants receiving benefits. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of participant applications. A review process over the eligibility requirements should occur and be documented, to ensure eligibility requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 005 Period of Performance Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure transactions for costs recorded for the end of the period of performance were not incurred after the period of performance for Federal awards. Additionally, manual journal entries should be supported by documentation for transactions that occurred during the period of performance. Condition: The County allocated costs to federal awards after the end of the period of performance. Documentation for manual adjusting journal entries was not maintained to ascertain transactions occurred during the period of performance. Questioned costs: $519,076 Context: 4 of 20 transactions tested were incurred after the period of performance end date. All 36 manual journal entries recorded to the programs did not have supporting documentation available. Cause: Costs were inadvertently claimed that fell outside the period of performance. Support for the accounting records could not be provided for the manual adjusting entries. Effect: May result in unallowable costs being charged to the Federal program. Repeat Finding: No Recommendation: We recommend the County review its procedures relative to allocating costs to Federal programs, and ensure only cost within the grant period are included. Supporting accounting records for manual adjusting journal entries should be maintained to support transactions incurred, with a documented approval process. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 006 Cash Management Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Material Noncompliance (Modified Opinion) Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the draw down request are supported by documentation of expenditures that been incurred. Additionally, the time between drawing and disbursing federal funds should be minimized and interest should be calculated on amounts of unearned revenue. Condition: Supporting documentation for the cash drawdown requests were not maintained. There were instances in which the accounting records did not agree to the grant cash draw request. The time between drawing and disbursing federal funds was not minimized and interest on unearned revenue was not calculated. Documentation of review and approval by an individual other than the preparer was not retained. Questioned costs: $198,122 Context: 5 of 5 cash draw down requests tested did not have supporting documentation of the exact amount drawn down maintained. Cause: Support for the draw down request could not be provided over the individual cash draw down request as it was not retained. Adjustments made to the project accounting records after the cash draw request were made caused the County to receive more funds than expenses incurred. Effect: Lack of proper documentation for reported information can lead to an over or under reimbursement of grant funds. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the draw request and documentation be retained. Reconciliations should be reviewed and approved by an individual other than the preparer at the time of the request and this documentation should be retained. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 007 Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILLIEA 10/1/2020; 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Numbers: 21-221038; 21-274038 Award Period: June 1, 2021 through September 30, 2022 and July 1, 2021 through September 30, 2022 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the quarterly financial reporting be supported by documentation of expenditures that have been incurred. In addition, grant agreements requiring grant close-out reports should reconcile to the accounting records. Condition: Supporting documentation for the quarterly financial reporting accounting records were not maintained. There was in instance in which the accounting records did not agree to the grant reconciliation submitted with the grant close-out package. Questioned costs: None Context: 3 of 4 quarterly financial reports tested did not have supporting documentation retained. 1 of 2 financial close out reports tested had accounting records that did not agree to the amounts reported. Cause: Support for the quarterly financial reports could not be provided as it was not retained. Adjustments made to the project accounting records after the close out report package was submitted caused the report to have inaccurate information. Effect: Lack of proper documentation for reported information can lead to an over or under reporting of grant expenditures. Repeat Finding: No Recommendation: We recommend the County design controls to ensure the accounting records reconcile to the quarterly financial reporting and grant close-out reports and documentation be retained. No financial activity should be recorded to the project accounting records after the grant close out report package is completed. Views of responsible officials: There is no disagreement with the audit finding.

2022 – 008 Eligibility Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Low-Income Home Energy Assistance Program (LIHEAP) Assistance Listing Number: 93.568 Federal Award Identification Number and Year: 2102ILE5C6 03/22/2021 Pass-Through Agency: Illinois Department of Commerce and Economic Opportunity Pass-Through Number: 21-274038 Award Period: July 1, 2021 through September 30, 2022 Type of Finding: • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include that participant file documentation and applications be reviewed for eligibility and this review should be documented. Condition: Participant files documents and application was reviewed by the intake coordinator for eligibility requirements but this review was not documented. Questioned costs: None Context: 1 of 60 tested did not have the application that was documented as reviewed by the intake coordinator. Cause: Management oversight. Effect: Lack of proper review over eligibility requirements could lead to ineligible participants receiving benefits. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of participant applications. A review process over the eligibility requirements should occur and be documented, to ensure eligibility requirements are being met. Views of responsible officials: There is no disagreement with the audit finding.