Audit 302287

(MATERIAL WEAKNESS) – SUSPENDED AND DEBARRED PARTIES – ALN 21.027 – COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Condition The County did not have an effective process in place to ensure subrecipients of pass-through federal awards were not suspended or debarred from participating in federally-supported programs. Criteria The Federal Compliance Supplement and 2 CFR Section 180.300 requires grant recipients and subrecipients to verify contractors and subrecipients are not suspended or debarred from performing covered transactions. Such verification may include 1) checking the System for Award Management (SAM) Exclusions; 2) collecting a certification from the entity or 3) adding a clause or condition to the covered transaction with that entity. Cause Management was not aware of how to search for suspended or debarred parties on the SAM.gov website and did not have procedures to include explicit language in its subrecipient contracts/agreements. Recommendation We recommend the County adopt controls to ensure contractors and subrecipients are not suspended or debarred. Questioned Costs None noted Views of Responsible Officials The county added information to the Payment Request Form to make sub recipients aware that their organization along with any respective Contractors need an active UEI and must be registered in SAM. Effect There is a risk the County could enter into covered transactions with suspended or debarred parties.

(MATERIAL WEAKNESS) – SUBRECIPIENT MONITORING– ALN 21.027 – COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Condition The County did not have an effective process in place to ensure required communications occur with subrecipients of federal awards. The agreements with the subrecipients did not explicitly include certain information required under 2 CFR 200.332(a)(1). Criteria The Federal Compliance Supplement and 2 CFR Section 200.332 requires pass-through entities to communicate and clearly identify to the subrecipient: 1) the award as a subaward at the time of the subaward by providing the information described in 2 CFR section 200.332(a)(1); 2) all requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and terms and conditions of the award; and 3) any additional requirements the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. It also requires the pass-through entity to verify that every subrecipient is audited under the Uniform Guidance when required. Cause Management was not aware of the additional communication requirements imposed on pass-through entities. Effect There is a risk of noncompliance with the subrecipient monitoring communications, as well as a risk the subrecipient(s) may not be audited in accordance with the Uniform Guidance when required. Recommendation We recommend the County update its communications with subrecipients to include the required communications of the subrecipients’ responsibilities under the federal requirements, grant agreements and award requirements including, but not limited to its audit obligations under the Uniform Guidance. Questioned Costs None noted Views of Responsible Officials The county added information to the Payment Request Form to ensure that sub recipients are aware of possible single audit requirements, active SAM registry and UEI.

(MATERIAL WEAKNESS) – SUSPENDED AND DEBARRED PARTIES – ALN 21.027 – COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Condition The County did not have an effective process in place to ensure subrecipients of pass-through federal awards were not suspended or debarred from participating in federally-supported programs. Criteria The Federal Compliance Supplement and 2 CFR Section 180.300 requires grant recipients and subrecipients to verify contractors and subrecipients are not suspended or debarred from performing covered transactions. Such verification may include 1) checking the System for Award Management (SAM) Exclusions; 2) collecting a certification from the entity or 3) adding a clause or condition to the covered transaction with that entity. Cause Management was not aware of how to search for suspended or debarred parties on the SAM.gov website and did not have procedures to include explicit language in its subrecipient contracts/agreements. Recommendation We recommend the County adopt controls to ensure contractors and subrecipients are not suspended or debarred. Questioned Costs None noted Views of Responsible Officials The county added information to the Payment Request Form to make sub recipients aware that their organization along with any respective Contractors need an active UEI and must be registered in SAM. Effect There is a risk the County could enter into covered transactions with suspended or debarred parties.

(MATERIAL WEAKNESS) – SUBRECIPIENT MONITORING– ALN 21.027 – COVID-19 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS Condition The County did not have an effective process in place to ensure required communications occur with subrecipients of federal awards. The agreements with the subrecipients did not explicitly include certain information required under 2 CFR 200.332(a)(1). Criteria The Federal Compliance Supplement and 2 CFR Section 200.332 requires pass-through entities to communicate and clearly identify to the subrecipient: 1) the award as a subaward at the time of the subaward by providing the information described in 2 CFR section 200.332(a)(1); 2) all requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and terms and conditions of the award; and 3) any additional requirements the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. It also requires the pass-through entity to verify that every subrecipient is audited under the Uniform Guidance when required. Cause Management was not aware of the additional communication requirements imposed on pass-through entities. Effect There is a risk of noncompliance with the subrecipient monitoring communications, as well as a risk the subrecipient(s) may not be audited in accordance with the Uniform Guidance when required. Recommendation We recommend the County update its communications with subrecipients to include the required communications of the subrecipients’ responsibilities under the federal requirements, grant agreements and award requirements including, but not limited to its audit obligations under the Uniform Guidance. Questioned Costs None noted Views of Responsible Officials The county added information to the Payment Request Form to ensure that sub recipients are aware of possible single audit requirements, active SAM registry and UEI.