FINDING 2023-001
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): SLFRP 3041
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
INDIANA STATE BOARD OF ACCOUNTS
13
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
Nonfederal entities and contractors are subject to nonprocurement suspension and debarment
regulations. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or are ineligible for participation in federal assistance
programs or activities. This is done by checking the Excluded Parties List System, collecting a certification
from the vendor, or adding a clause or condition to the covered transaction with the vendor.
There were two vendors subject to suspension and debarment requirements during the audit
period. Both vendors were selected for testing. The County did not perform procedures to ensure either
vendor was not suspended, debarred, or otherwise excluded from or ineligible for participation in federal
assistance programs or activities.
Additionally, the County did not have a formalized procurement policy outlining its processes and
procedures with regards to the procurement of goods and services using federal grant funds. The policy
must conform to the procurement standards identified in 2 CFR 200.317 through 200.327 and should
address ensuring vendors are not suspended or debarred prior to entering into covered transactions if the
contract is expected to equal or exceed $25,000.
The lack of internal controls was a systemic issue throughout the audit period and enabled material
noncompliance to occur and remain undetected.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
31 CFR 19.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the EPLS; or
(b) Collecting a certification from that person if allowed by this rule; or
(c) Adding a clause or condition to the covered transaction with that person."
INDIANA STATE BOARD OF ACCOUNTS
14
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
2 CFR 200.318(a) states:
"The non-Federal entity must have and use documented procurement procedures, consistent
with State, local, and tribal laws and regulations and the standards of this section, for the
acquisition of property or services required under a Federal award or subaward. The non-
Federal entity's documented procurement procedures must conform to the procurement
standards identified in §§ 200.317 through 200.327."
Cause
A proper system of internal controls was not designed by management of the County. Embedded
within a properly designed and implemented internal control system should be internal controls consisting
of policies and procedures. Policies reflect the County's management statements of what should be done
to effect internal controls, and procedures should consist of actions that would implement these policies.
Effect
Without the proper design and implementation of an effectively designed system of internal
controls, the County cannot ensure the vendors paid with federal funds are eligible to participate in federal
programs. Any program funds the County used to pay contractors that have been suspended or debarred
would be unallowable, and the funding agency could potentially recover them. Furthermore, with
adequately designed and implemented policies that reflect the federal regulations as required, the County
cannot ensure that goods and services paid with federal funds are properly procured.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County establish a system of internal controls to ensure
that verifications are performed to determine whether each contractor has been suspended or debarred
from participating in federal contracts prior to making payment. In addition, we recommended the County
develop a procurement policy that addresses and adheres to the federal requirements outlined in regulations.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): SLFRP 3041
Compliance Requirement: Reporting
Audit Finding: Material Weakness
INDIANA STATE BOARD OF ACCOUNTS
15
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to
the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates
are based upon type of recipient and its population, as well as the recipient's allocation amount. Information
to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period.
The County was classified as a metropolitan county with a population below 250,000 residents that
received an allocation of less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery
Funds funding. As such, the initial P&E report, covering the period from March 3, 2021 to March 31, 2022,
was required to be submitted to the Treasury by April 30, 2022. The subsequent annual reports are to
cover one calendar year and must be submitted to the Treasury by April 30 each year.
The County had not designed or implemented a system of internal controls to ensure the annual
P&E report due April 30, 2023, was complete and accurate prior to submission. One County official
prepared and submitted the annual P&E report to the Treasury without a documented oversight, review, or
approval process in place to ensure its accuracy.
The lack of internal controls was isolated to the P&E report due April 30, 2023, for the fiscal
reporting year ending March 31, 2023.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
Cause
A proper system of internal controls was not designed by management of the County, which would
include segregation of key functions. Embedded within a properly designed and implemented internal
control system should be internal controls consisting of policies and procedures. Policies reflect the
County's management of what should be done to effect internal controls, and procedures should consist of
actions that would implement these policies.
Effect
Without the proper implementation of an effectively designed system of internal controls, including
policies and procedures that provide segregation of duties and additional oversight as needed, the internal
control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance.
It also placed the County at risk of noncompliance with the grant agreement and could result in
failure to file a report, filing late, or filing an inaccurate report with the grantor agency.
INDIANA STATE BOARD OF ACCOUNTS
16
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County design and implement a proper system of
internal controls, including policies and procedures that would provide segregation of duties to ensure
appropriate reviews, approvals, and oversight are taking place.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-001
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): SLFRP 3041
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
INDIANA STATE BOARD OF ACCOUNTS
13
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
Nonfederal entities and contractors are subject to nonprocurement suspension and debarment
regulations. These regulations restrict awards, subawards, and contracts with certain parties that are
debarred, suspended, or otherwise excluded from or are ineligible for participation in federal assistance
programs or activities. This is done by checking the Excluded Parties List System, collecting a certification
from the vendor, or adding a clause or condition to the covered transaction with the vendor.
There were two vendors subject to suspension and debarment requirements during the audit
period. Both vendors were selected for testing. The County did not perform procedures to ensure either
vendor was not suspended, debarred, or otherwise excluded from or ineligible for participation in federal
assistance programs or activities.
Additionally, the County did not have a formalized procurement policy outlining its processes and
procedures with regards to the procurement of goods and services using federal grant funds. The policy
must conform to the procurement standards identified in 2 CFR 200.317 through 200.327 and should
address ensuring vendors are not suspended or debarred prior to entering into covered transactions if the
contract is expected to equal or exceed $25,000.
The lack of internal controls was a systemic issue throughout the audit period and enabled material
noncompliance to occur and remain undetected.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
31 CFR 19.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
(a) Checking the EPLS; or
(b) Collecting a certification from that person if allowed by this rule; or
(c) Adding a clause or condition to the covered transaction with that person."
INDIANA STATE BOARD OF ACCOUNTS
14
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
2 CFR 200.318(a) states:
"The non-Federal entity must have and use documented procurement procedures, consistent
with State, local, and tribal laws and regulations and the standards of this section, for the
acquisition of property or services required under a Federal award or subaward. The non-
Federal entity's documented procurement procedures must conform to the procurement
standards identified in §§ 200.317 through 200.327."
Cause
A proper system of internal controls was not designed by management of the County. Embedded
within a properly designed and implemented internal control system should be internal controls consisting
of policies and procedures. Policies reflect the County's management statements of what should be done
to effect internal controls, and procedures should consist of actions that would implement these policies.
Effect
Without the proper design and implementation of an effectively designed system of internal
controls, the County cannot ensure the vendors paid with federal funds are eligible to participate in federal
programs. Any program funds the County used to pay contractors that have been suspended or debarred
would be unallowable, and the funding agency could potentially recover them. Furthermore, with
adequately designed and implemented policies that reflect the federal regulations as required, the County
cannot ensure that goods and services paid with federal funds are properly procured.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County establish a system of internal controls to ensure
that verifications are performed to determine whether each contractor has been suspended or debarred
from participating in federal contracts prior to making payment. In addition, we recommended the County
develop a procurement policy that addresses and adheres to the federal requirements outlined in regulations.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): SLFRP 3041
Compliance Requirement: Reporting
Audit Finding: Material Weakness
INDIANA STATE BOARD OF ACCOUNTS
15
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to
the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates
are based upon type of recipient and its population, as well as the recipient's allocation amount. Information
to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period.
The County was classified as a metropolitan county with a population below 250,000 residents that
received an allocation of less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery
Funds funding. As such, the initial P&E report, covering the period from March 3, 2021 to March 31, 2022,
was required to be submitted to the Treasury by April 30, 2022. The subsequent annual reports are to
cover one calendar year and must be submitted to the Treasury by April 30 each year.
The County had not designed or implemented a system of internal controls to ensure the annual
P&E report due April 30, 2023, was complete and accurate prior to submission. One County official
prepared and submitted the annual P&E report to the Treasury without a documented oversight, review, or
approval process in place to ensure its accuracy.
The lack of internal controls was isolated to the P&E report due April 30, 2023, for the fiscal
reporting year ending March 31, 2023.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
Cause
A proper system of internal controls was not designed by management of the County, which would
include segregation of key functions. Embedded within a properly designed and implemented internal
control system should be internal controls consisting of policies and procedures. Policies reflect the
County's management of what should be done to effect internal controls, and procedures should consist of
actions that would implement these policies.
Effect
Without the proper implementation of an effectively designed system of internal controls, including
policies and procedures that provide segregation of duties and additional oversight as needed, the internal
control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance.
It also placed the County at risk of noncompliance with the grant agreement and could result in
failure to file a report, filing late, or filing an inaccurate report with the grantor agency.
INDIANA STATE BOARD OF ACCOUNTS
16
VERMILLION COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County design and implement a proper system of
internal controls, including policies and procedures that would provide segregation of duties to ensure
appropriate reviews, approvals, and oversight are taking place.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.