Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering into a covered transaction.
Condition: The County did not retain documentation that the verification of suspended and debarred vendors was completed.
Questioned Costs: Unknown.
Context: For one of one transaction tested for suspension and debarment, the County did not retain documentation that the procedures were done.
Cause: Management oversight.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-004 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering into a covered transaction.
Condition: The County did not retain documentation that the verification of suspended and debarred vendors was completed.
Questioned Costs: Unknown.
Context: For one of one transaction tested for suspension and debarment, the County did not retain documentation that the procedures were done.
Cause: Management oversight.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-004 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering into a covered transaction.
Condition: The County did not retain documentation that the verification of suspended and debarred vendors was completed.
Questioned Costs: Unknown.
Context: For one of one transaction tested for suspension and debarment, the County did not retain documentation that the procedures were done.
Cause: Management oversight.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-004 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Special Provisions
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The County is required to properly input income documentation in the state MAXIS system.
Condition: Income information entered not the state MAXIS system did not match the support documentation retained by the County to support the amount.
Questioned Costs: Unknown.
Context: For one of sixty casefiles tested, it was noted that income information entered into the state MAXIS system did not match the supporting documentation retained by the County to support the amount.
Cause: Lack of oversight by management.
Effect: Benefits could be provided to ineligible clients.
Repeat Finding: Prior year finding identified as Finding 2022-006.
Recommendation: We recommend that income verification be reviewed for each eligible case file to ensure the information matches MAXIS.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Special Provisions
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The County is required to properly input income documentation in the state MAXIS system.
Condition: Income information entered not the state MAXIS system did not match the support documentation retained by the County to support the amount.
Questioned Costs: Unknown.
Context: For one of sixty casefiles tested, it was noted that income information entered into the state MAXIS system did not match the supporting documentation retained by the County to support the amount.
Cause: Lack of oversight by management.
Effect: Benefits could be provided to ineligible clients.
Repeat Finding: Prior year finding identified as Finding 2022-006.
Recommendation: We recommend that income verification be reviewed for each eligible case file to ensure the information matches MAXIS.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Special Provisions
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The County is required to properly input income documentation in the state MAXIS system.
Condition: Income information entered not the state MAXIS system did not match the support documentation retained by the County to support the amount.
Questioned Costs: Unknown.
Context: For one of sixty casefiles tested, it was noted that income information entered into the state MAXIS system did not match the supporting documentation retained by the County to support the amount.
Cause: Lack of oversight by management.
Effect: Benefits could be provided to ineligible clients.
Repeat Finding: Prior year finding identified as Finding 2022-006.
Recommendation: We recommend that income verification be reviewed for each eligible case file to ensure the information matches MAXIS.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: COVID-19 Community Development Block Grants
Assistance Listing Number: 14.228
Federal Award Identification Number and Year: B-20-DW-27-0001, 2023
Pass-Through Agency: Minnesota Department of Employment and Economic Development, Business and Community Development Division
Pass-Through Number: B-20-DW-27-0001
Compliance Requirement Affected: Reporting
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: Recipients of $150,000 or more of grant funds must submit, no later than 7 days after the end of each calendar quarter, a quarterly report to the State. Quarterly reports mush be in accordance with reporting requirements set forth in section 15011 of the CARES Act. The Grantee will monitor the activities of the sub-recipient according to 2 CFR §200.303 and 2 CFR §200.331 as necessary to ensure that the sub-award is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the sub-award; and that sub-award performance goals are achieved. This includes reviewing financial and programmatic reports required by the pass-through entity.
Condition: Proper records were not retained for reports and there was no oversight by County management of the reports being submitted by the subrecipient to the State.
Questioned Costs: None noted.
Context: For one of two quarterly reports tested, there was no record on file for the report that was submitted. For one of two quarterly reports tested, the report was not submitted by the deadline listed in the grant agreement. For all reports, it was noted that there was no review by County management of the reports submitted by the subrecipient and the County received a copy of the report at the same time as the submission was completed.
Cause: Insufficient management oversight.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County reviews their policies to ensure reporting requirements are met including a review of the subrecipient reports prior to submission.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: COVID-19 Community Development Block Grants
Assistance Listing Number: 14.228
Federal Award Identification Number and Year: B-20-DW-27-0001, 2023
Pass-Through Agency: Minnesota Department of Employment and Economic Development, Business and Community Development Division
Pass-Through Number: B-20-DW-27-0001
Compliance Requirement Affected: Subrecipient Monitoring
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: The grantee will monitor the activities of the sub-recipient according to 2 CFR §200.303 and 2 CFR §200.331 as necessary to ensure that the sub-award is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the sub-award; and that sub-award performance goals are achieved.
Condition: Proper records were not retained as required by subrecipient monitoring purposes.
Questioned Costs: None noted.
Context: There are no monitoring policies or procedures in place at the County. There was no documentation on file to support that the County monitored the subrecipient to ensure they used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward or that the subrecipient audits were completed in accordance with requirements.
Cause: Insufficient management oversight.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County reviews their policies to ensure they are monitoring subrecipients and retaining documentation as required by federal guidelines.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2889, 2023
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering a covered transaction.
Condition: The County did not retain documentation for the date that the verification was done.
Questioned Costs: Unknown.
Context: For one of five transactions tested for suspension and debarment, the County retained documentation the procedures were done; however, the date of verification was not kept on file to support verification was done prior to the transaction taking place. Also, for one of five transactions tested for suspension and debarment, the County did not have documentation that the verification was done.
Cause: County policy does not align with federal requirements.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-003 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2889, 2023
Compliance Requirement Affected: Reporting
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Treasury, the County is required to submit a quarterly project and expense report containing the expenditures incurred during each quarter.
Condition: The County did not submit all expenditures related to 2023 in the quarterly reports related to 2023.
Questioned Costs: None noted.
Context: The 4th quarter Project and Expenditure report filed was missing $600,000 of pass-through costs incurred by the County for a project.
Cause: The federal reporting website did not allow the County to retrieve all necessary information timely necessary for the report and the reporting window closed before the necessary information was gathered.
Effect: Expenditures could be claimed in the wrong period.
Repeat Finding: No.
Recommendation: We recommend that the County review their policies and federal requirements to ensure all costs incurred are reported timely.
Views of responsible officials: This finding was due to reporting system issues which caused the County’s inability to report this project expenditure in the 4th quarter of 2023.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2889, 2023
Compliance Requirement Affected: Earmarking
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the Final Rule, recipients can elect a one-time “standard allowance” of $10 million (not to exceed the recipient’s award amount) to spend on the “provision of government services” during the period of performance. Treasury has determined that there are no subawards under the revenue loss category allowed for eligible use. The definition of subrecipient in the Uniform Guidance provides that a subaward is provided for the purpose of “carrying out” a portion of a federal award. Recipients’ use of revenue loss funds does not give rise to subrecipient relationships.
Condition: The County granted subawards with "revenue loss" money.
Questioned Costs: None noted.
Context: Out of the total expenditures reported in 2023, $122,330 granted as subawards was reported under “revenue loss” instead of the specific projects they were allowable under.
Cause: Management oversight.
Effect: The County could be claiming expenditures on their quarterly reports in the incorrect projects.
Repeat Finding: No.
Recommendation: We recommend that the County reviews their policies and federal requirements to ensure all costs are reported under the correct category.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Federal guidelines require grant recipients to implement internal controls for each direct and material compliance requirement applicable to the federal grant to ensure compliance with said requirements.
Condition: No internal casefile reviews were completed for public health or Diversionary Work Program (DWP) recipients.
Questioned Costs: None noted.
Context: There was no internal casefile review process in place for public health or DWP casefiles.
Cause: Management unaware of the requirement.
Effect: Casefiles could be incomplete or inaccurate and subsequently, benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to ensure casefiles are reviewed and documented for public health and DWP recipients.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Allowable Costs and Allowable Activities
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: The County is required to keep documentation of reviews and approvals on file for all disbursements and journal entries to ensure proper monitoring and approval of expenditures coded to the grant.
Condition: Not all general disbursements or journal entries tested had documentation of a review by a supervisor on file.
Questioned Costs: Unknown.
Context: For seven of forty disbursements tested, there was no documentation of a supervisor reviewing the grant expenditures.
Cause: Lack of oversight by management.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County has a supervisor sign off on all disbursements and journal entries to ensure proper review of expenditures.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services, proper records should be kept in place to support compliance with eligibility.
Condition: Public health casefiles tested did not have the proper supporting documentation for eligibility determination.
Questioned Costs: Unknown.
Context: Three of eight public health casefiles tested did not have proper supporting documentation for eligibility determination.
Cause: Lack of oversight by management.
Effect: Benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to verify proper documentation is kept on file for all clients deemed eligible.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Earmarking
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services and the Minnesota Department of Human Services, all administrative expenditures reported on the grant must be under 7.5% of total expenditures submitted on the quarterly DWP reports.
Condition: Quarterly DWP reports had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Questioned Costs: None noted.
Context: One out of two quarterly 2902 DWP reports tested had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Cause: County policy does not align with federal requirements.
Effect: Ineligible expenses could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County implements a policy to review this requirement on a quarterly basis.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Federal guidelines require grant recipients to implement internal controls for each direct and material compliance requirement applicable to the federal grant to ensure compliance with said requirements.
Condition: No internal casefile reviews were completed for public health or Diversionary Work Program (DWP) recipients.
Questioned Costs: None noted.
Context: There was no internal casefile review process in place for public health or DWP casefiles.
Cause: Management unaware of the requirement.
Effect: Casefiles could be incomplete or inaccurate and subsequently, benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to ensure casefiles are reviewed and documented for public health and DWP recipients.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Allowable Costs and Allowable Activities
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: The County is required to keep documentation of reviews and approvals on file for all disbursements and journal entries to ensure proper monitoring and approval of expenditures coded to the grant.
Condition: Not all general disbursements or journal entries tested had documentation of a review by a supervisor on file.
Questioned Costs: Unknown.
Context: For seven of forty disbursements tested, there was no documentation of a supervisor reviewing the grant expenditures.
Cause: Lack of oversight by management.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County has a supervisor sign off on all disbursements and journal entries to ensure proper review of expenditures.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services, proper records should be kept in place to support compliance with eligibility.
Condition: Public health casefiles tested did not have the proper supporting documentation for eligibility determination.
Questioned Costs: Unknown.
Context: Three of eight public health casefiles tested did not have proper supporting documentation for eligibility determination.
Cause: Lack of oversight by management.
Effect: Benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to verify proper documentation is kept on file for all clients deemed eligible.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Earmarking
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services and the Minnesota Department of Human Services, all administrative expenditures reported on the grant must be under 7.5% of total expenditures submitted on the quarterly DWP reports.
Condition: Quarterly DWP reports had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Questioned Costs: None noted.
Context: One out of two quarterly 2902 DWP reports tested had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Cause: County policy does not align with federal requirements.
Effect: Ineligible expenses could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County implements a policy to review this requirement on a quarterly basis.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering into a covered transaction.
Condition: The County did not retain documentation that the verification of suspended and debarred vendors was completed.
Questioned Costs: Unknown.
Context: For one of one transaction tested for suspension and debarment, the County did not retain documentation that the procedures were done.
Cause: Management oversight.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-004 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering into a covered transaction.
Condition: The County did not retain documentation that the verification of suspended and debarred vendors was completed.
Questioned Costs: Unknown.
Context: For one of one transaction tested for suspension and debarment, the County did not retain documentation that the procedures were done.
Cause: Management oversight.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-004 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering into a covered transaction.
Condition: The County did not retain documentation that the verification of suspended and debarred vendors was completed.
Questioned Costs: Unknown.
Context: For one of one transaction tested for suspension and debarment, the County did not retain documentation that the procedures were done.
Cause: Management oversight.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-004 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Special Provisions
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The County is required to properly input income documentation in the state MAXIS system.
Condition: Income information entered not the state MAXIS system did not match the support documentation retained by the County to support the amount.
Questioned Costs: Unknown.
Context: For one of sixty casefiles tested, it was noted that income information entered into the state MAXIS system did not match the supporting documentation retained by the County to support the amount.
Cause: Lack of oversight by management.
Effect: Benefits could be provided to ineligible clients.
Repeat Finding: Prior year finding identified as Finding 2022-006.
Recommendation: We recommend that income verification be reviewed for each eligible case file to ensure the information matches MAXIS.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Special Provisions
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The County is required to properly input income documentation in the state MAXIS system.
Condition: Income information entered not the state MAXIS system did not match the support documentation retained by the County to support the amount.
Questioned Costs: Unknown.
Context: For one of sixty casefiles tested, it was noted that income information entered into the state MAXIS system did not match the supporting documentation retained by the County to support the amount.
Cause: Lack of oversight by management.
Effect: Benefits could be provided to ineligible clients.
Repeat Finding: Prior year finding identified as Finding 2022-006.
Recommendation: We recommend that income verification be reviewed for each eligible case file to ensure the information matches MAXIS.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Agriculture
Federal Program Name: State Administrative Matching Grants for Supplemental Nutrition Assistance Program (SNAP Cluster)
Assistance Listing Number: 10.561
Federal Award Identification Number and Year: 232MN101S2514, 232MN101S2520, 232MN127Q7503, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 232MN101S2514, 232MN101S2520, 232MN127Q7503
Compliance Requirement Affected: Special Provisions
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: The County is required to properly input income documentation in the state MAXIS system.
Condition: Income information entered not the state MAXIS system did not match the support documentation retained by the County to support the amount.
Questioned Costs: Unknown.
Context: For one of sixty casefiles tested, it was noted that income information entered into the state MAXIS system did not match the supporting documentation retained by the County to support the amount.
Cause: Lack of oversight by management.
Effect: Benefits could be provided to ineligible clients.
Repeat Finding: Prior year finding identified as Finding 2022-006.
Recommendation: We recommend that income verification be reviewed for each eligible case file to ensure the information matches MAXIS.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: COVID-19 Community Development Block Grants
Assistance Listing Number: 14.228
Federal Award Identification Number and Year: B-20-DW-27-0001, 2023
Pass-Through Agency: Minnesota Department of Employment and Economic Development, Business and Community Development Division
Pass-Through Number: B-20-DW-27-0001
Compliance Requirement Affected: Reporting
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: Recipients of $150,000 or more of grant funds must submit, no later than 7 days after the end of each calendar quarter, a quarterly report to the State. Quarterly reports mush be in accordance with reporting requirements set forth in section 15011 of the CARES Act. The Grantee will monitor the activities of the sub-recipient according to 2 CFR §200.303 and 2 CFR §200.331 as necessary to ensure that the sub-award is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the sub-award; and that sub-award performance goals are achieved. This includes reviewing financial and programmatic reports required by the pass-through entity.
Condition: Proper records were not retained for reports and there was no oversight by County management of the reports being submitted by the subrecipient to the State.
Questioned Costs: None noted.
Context: For one of two quarterly reports tested, there was no record on file for the report that was submitted. For one of two quarterly reports tested, the report was not submitted by the deadline listed in the grant agreement. For all reports, it was noted that there was no review by County management of the reports submitted by the subrecipient and the County received a copy of the report at the same time as the submission was completed.
Cause: Insufficient management oversight.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County reviews their policies to ensure reporting requirements are met including a review of the subrecipient reports prior to submission.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Housing and Urban Development
Federal Program Name: COVID-19 Community Development Block Grants
Assistance Listing Number: 14.228
Federal Award Identification Number and Year: B-20-DW-27-0001, 2023
Pass-Through Agency: Minnesota Department of Employment and Economic Development, Business and Community Development Division
Pass-Through Number: B-20-DW-27-0001
Compliance Requirement Affected: Subrecipient Monitoring
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: The grantee will monitor the activities of the sub-recipient according to 2 CFR §200.303 and 2 CFR §200.331 as necessary to ensure that the sub-award is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the sub-award; and that sub-award performance goals are achieved.
Condition: Proper records were not retained as required by subrecipient monitoring purposes.
Questioned Costs: None noted.
Context: There are no monitoring policies or procedures in place at the County. There was no documentation on file to support that the County monitored the subrecipient to ensure they used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward or that the subrecipient audits were completed in accordance with requirements.
Cause: Insufficient management oversight.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County reviews their policies to ensure they are monitoring subrecipients and retaining documentation as required by federal guidelines.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2889, 2023
Compliance Requirement Affected: Suspension and Debarment
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: According to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering a covered transaction.
Condition: The County did not retain documentation for the date that the verification was done.
Questioned Costs: Unknown.
Context: For one of five transactions tested for suspension and debarment, the County retained documentation the procedures were done; however, the date of verification was not kept on file to support verification was done prior to the transaction taking place. Also, for one of five transactions tested for suspension and debarment, the County did not have documentation that the verification was done.
Cause: County policy does not align with federal requirements.
Effect: County could be using a vendor that is suspended or debarred at the time of the transaction.
Repeat Finding: Prior year finding identified as Finding 2022-003 (procurement portion resolved).
Recommendation: We recommend the County align their county-wide policies to address any necessary modifications to ensure all suspension and debarment requirements are met.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2889, 2023
Compliance Requirement Affected: Reporting
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Treasury, the County is required to submit a quarterly project and expense report containing the expenditures incurred during each quarter.
Condition: The County did not submit all expenditures related to 2023 in the quarterly reports related to 2023.
Questioned Costs: None noted.
Context: The 4th quarter Project and Expenditure report filed was missing $600,000 of pass-through costs incurred by the County for a project.
Cause: The federal reporting website did not allow the County to retrieve all necessary information timely necessary for the report and the reporting window closed before the necessary information was gathered.
Effect: Expenditures could be claimed in the wrong period.
Repeat Finding: No.
Recommendation: We recommend that the County review their policies and federal requirements to ensure all costs incurred are reported timely.
Views of responsible officials: This finding was due to reporting system issues which caused the County’s inability to report this project expenditure in the 4th quarter of 2023.
Federal Agency: U.S. Department of the Treasury
Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF)
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP2889, 2023
Compliance Requirement Affected: Earmarking
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the Final Rule, recipients can elect a one-time “standard allowance” of $10 million (not to exceed the recipient’s award amount) to spend on the “provision of government services” during the period of performance. Treasury has determined that there are no subawards under the revenue loss category allowed for eligible use. The definition of subrecipient in the Uniform Guidance provides that a subaward is provided for the purpose of “carrying out” a portion of a federal award. Recipients’ use of revenue loss funds does not give rise to subrecipient relationships.
Condition: The County granted subawards with "revenue loss" money.
Questioned Costs: None noted.
Context: Out of the total expenditures reported in 2023, $122,330 granted as subawards was reported under “revenue loss” instead of the specific projects they were allowable under.
Cause: Management oversight.
Effect: The County could be claiming expenditures on their quarterly reports in the incorrect projects.
Repeat Finding: No.
Recommendation: We recommend that the County reviews their policies and federal requirements to ensure all costs are reported under the correct category.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Federal guidelines require grant recipients to implement internal controls for each direct and material compliance requirement applicable to the federal grant to ensure compliance with said requirements.
Condition: No internal casefile reviews were completed for public health or Diversionary Work Program (DWP) recipients.
Questioned Costs: None noted.
Context: There was no internal casefile review process in place for public health or DWP casefiles.
Cause: Management unaware of the requirement.
Effect: Casefiles could be incomplete or inaccurate and subsequently, benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to ensure casefiles are reviewed and documented for public health and DWP recipients.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Allowable Costs and Allowable Activities
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: The County is required to keep documentation of reviews and approvals on file for all disbursements and journal entries to ensure proper monitoring and approval of expenditures coded to the grant.
Condition: Not all general disbursements or journal entries tested had documentation of a review by a supervisor on file.
Questioned Costs: Unknown.
Context: For seven of forty disbursements tested, there was no documentation of a supervisor reviewing the grant expenditures.
Cause: Lack of oversight by management.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County has a supervisor sign off on all disbursements and journal entries to ensure proper review of expenditures.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services, proper records should be kept in place to support compliance with eligibility.
Condition: Public health casefiles tested did not have the proper supporting documentation for eligibility determination.
Questioned Costs: Unknown.
Context: Three of eight public health casefiles tested did not have proper supporting documentation for eligibility determination.
Cause: Lack of oversight by management.
Effect: Benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to verify proper documentation is kept on file for all clients deemed eligible.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Earmarking
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services and the Minnesota Department of Human Services, all administrative expenditures reported on the grant must be under 7.5% of total expenditures submitted on the quarterly DWP reports.
Condition: Quarterly DWP reports had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Questioned Costs: None noted.
Context: One out of two quarterly 2902 DWP reports tested had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Cause: County policy does not align with federal requirements.
Effect: Ineligible expenses could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County implements a policy to review this requirement on a quarterly basis.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance
Criteria or Specific Requirement: Federal guidelines require grant recipients to implement internal controls for each direct and material compliance requirement applicable to the federal grant to ensure compliance with said requirements.
Condition: No internal casefile reviews were completed for public health or Diversionary Work Program (DWP) recipients.
Questioned Costs: None noted.
Context: There was no internal casefile review process in place for public health or DWP casefiles.
Cause: Management unaware of the requirement.
Effect: Casefiles could be incomplete or inaccurate and subsequently, benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to ensure casefiles are reviewed and documented for public health and DWP recipients.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Allowable Costs and Allowable Activities
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: The County is required to keep documentation of reviews and approvals on file for all disbursements and journal entries to ensure proper monitoring and approval of expenditures coded to the grant.
Condition: Not all general disbursements or journal entries tested had documentation of a review by a supervisor on file.
Questioned Costs: Unknown.
Context: For seven of forty disbursements tested, there was no documentation of a supervisor reviewing the grant expenditures.
Cause: Lack of oversight by management.
Effect: Ineligible costs could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County has a supervisor sign off on all disbursements and journal entries to ensure proper review of expenditures.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services and Minnesota Department of Public Health
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Eligibility
Award Period: Year Ended December 31, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services, proper records should be kept in place to support compliance with eligibility.
Condition: Public health casefiles tested did not have the proper supporting documentation for eligibility determination.
Questioned Costs: Unknown.
Context: Three of eight public health casefiles tested did not have proper supporting documentation for eligibility determination.
Cause: Lack of oversight by management.
Effect: Benefits could be provided for ineligible clients.
Repeat Finding: No.
Recommendation: We recommend that the County aligns their policies to verify proper documentation is kept on file for all clients deemed eligible.
Views of responsible officials: There is no disagreement with the audit finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Temporary Assistance for Needy Families
Assistance Listing Number: 93.558
Federal Award Identification Number and Year: 2301MNTANF, 2023
Pass-Through Agency: Minnesota Department of Human Services
Pass-Through Numbers: 2301MNTANF
Compliance Requirement Affected: Earmarking
Award Period: Year Ended December 31, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement: Under the compliance and reporting guidance issued by the Department of the Health and Human Services and the Minnesota Department of Human Services, all administrative expenditures reported on the grant must be under 7.5% of total expenditures submitted on the quarterly DWP reports.
Condition: Quarterly DWP reports had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Questioned Costs: None noted.
Context: One out of two quarterly 2902 DWP reports tested had administrative expenditures that were more than 7.5% of the total expenditures submitted.
Cause: County policy does not align with federal requirements.
Effect: Ineligible expenses could be reported.
Repeat Finding: No.
Recommendation: We recommend that the County implements a policy to review this requirement on a quarterly basis.
Views of responsible officials: There is no disagreement with the audit finding.