Audit 300633

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

2023-004 Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No. and Year: Various Compliance Requirement: Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Per Title 42 USC 254b(k)(3)(F), the Center has made or will make and will continue to make every reasonable effort to collect appropriate reimbursement for its costs in providing health services to persons who are entitled to insurance benefits under title XVIII of the Social Security Act [42 U.S.C. 1395 et seq.], to medical assistance under a State plan approved under title XIX of such Act [42 U.S.C. 1396 et seq.], or to assistance for medical expenses under any other public assistance program or private health insurance program; (G) the center—(i) has prepared a schedule of fees or payments for the provision of its services consistent with locally prevailing rates or charges and designed to cover its reasonable costs of operation and has prepared a corresponding schedule of discounts to be applied to the payment of such fees or payments, which discounts are adjusted on the basis of the patient’s ability to pay; (ii) has made and will continue to make every reasonable effort—(I) to secure from patients payment for services in accordance with such schedules. Condition: We noted 6 instances out of 93 where the County did not appropriately adjust patient charges based on the Health Center’s sliding fee discount program schedules in accordance with 42 USC 254b(k)(3)(F). Cause: The condition is primarily caused by the County not following the policies and procedures in place to ensure the sliding fee discounts to patient charges were applied consistent with its sliding fee discount program schedules. Effect: Discounts applied to patient charges were inconsistent with its sliding fee discount program schedules. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 93 participants out of 11,862 participants were selected for testing. The condition noted above was identified during our procedures over the County’s sliding fee discount program procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its established policies and procedures to ensure the sliding fee discount program schedules are applied to patient charges consistent with its sliding fee discount schedules and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.