Audit 301557

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires 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. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires 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. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires 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. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires 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. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires 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. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires 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. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.