FAC Explorer

Audit 318475

FY End
2023-12-31
Total Expended
$92.64M
Findings
14
Programs
60
Organization: Brown County, Wisconsin (WI)
Year: 2023 Accepted: 2024-09-04
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
485663 2023-002 Significant Deficiency Yes I
485664 2023-002 Significant Deficiency Yes I
485665 2023-002 Significant Deficiency Yes I
485666 2023-002 Significant Deficiency Yes I
485667 2023-002 Significant Deficiency Yes I
485668 2023-002 Significant Deficiency Yes I
485669 2023-002 Significant Deficiency Yes I
1062105 2023-002 Significant Deficiency Yes I
1062106 2023-002 Significant Deficiency Yes I
1062107 2023-002 Significant Deficiency Yes I
1062108 2023-002 Significant Deficiency Yes I
1062109 2023-002 Significant Deficiency Yes I
1062110 2023-002 Significant Deficiency Yes I
1062111 2023-002 Significant Deficiency Yes I

Programs

ALN Program Spent Major Findings
21.027 Coronavirus State and Local Fiscal Recovery Funds $45.29M Yes 1
21.023 Emergency Rental Assistance Program $3.90M - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1.83M - 0
93.778 Medical Assistance Program $970,515 - 0
84.425 Education Stabilization Fund $503,590 - 0
20.205 Highway Planning and Construction $351,249 - 0
84.181 Special Education-Grants for Infants and Families $297,115 - 0
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $295,856 - 0
16.585 Drug Court Discretionary Grant Program $230,578 - 0
93.090 Guardianship Assistance $195,498 - 0
93.658 Foster Care_title IV-E $151,666 - 0
93.767 Children's Health Insurance Program $145,879 - 0
20.106 Airport Improvement Program $141,783 - 0
15.658 Natural Resource Damage Assessment, Restoration and Implementation $135,367 - 0
95.001 High Intensity Drug Trafficking Areas Program $134,335 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $131,810 - 0
97.042 Emergency Management Performance Grants $122,204 - 0
16.588 Violence Against Women Formula Grants $106,237 - 0
10.902 Soil and Water Conservation $97,938 - 0
93.994 Maternal and Child Health Services Block Grant to the States $95,204 - 0
16.575 Crime Victim Assistance $92,220 - 0
93.563 Child Support Enforcement $81,189 - 0
16.922 Equitable Sharing Program $74,091 - 0
16.606 State Criminal Alien Assistance Program $67,665 - 0
93.556 Promoting Safe and Stable Families $66,620 - 0
16.738 Edward Byrne Memorial Justice Assistance Grant Program $49,024 - 0
11.473 Office for Coastal Management $48,791 - 0
93.558 Temporary Assistance for Needy Families $41,213 - 0
93.747 Elder Abuse Prevention Interventions Program $37,994 - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $37,366 - 0
66.454 Water Quality Management Planning $30,000 - 0
93.659 Adoption Assistance $29,367 - 0
93.268 Immunization Cooperative Agreements $27,160 - 0
93.597 Grants to States for Access and Visitation Programs $26,364 - 0
93.958 Block Grants for Community Mental Health Services $25,717 - 0
93.667 Social Services Block Grant $24,778 - 0
93.568 Low-Income Home Energy Assistance $24,719 - 0
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $20,002 - 0
93.991 Preventive Health and Health Services Block Grant $19,423 - 0
66.469 Great Lakes Program $17,345 - 0
10.912 Environmental Quality Incentives Program $17,260 - 0
14.218 Community Development Block Grants/entitlement Grants $17,000 - 0
66.460 Nonpoint Source Implementation Grants $16,828 - 0
20.600 State and Community Highway Safety $12,881 - 0
16.710 Public Safety Partnership and Community Policing Grants $11,783 - 0
10.555 National School Lunch Program $11,533 - 0
93.645 Stephanie Tubbs Jones Child Welfare Services Program $9,304 - 0
93.788 Opioid Str $8,949 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $7,748 - 0
97.067 Homeland Security Grant Program $7,500 - 0
20.616 National Priority Safety Programs $7,265 - 0
93.575 Child Care and Development Block Grant $6,400 - 0
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $5,856 - 0
10.553 School Breakfast Program $5,833 - 0
16.543 Missing Children's Assistance $4,340 - 0
93.069 Public Health Emergency Preparedness $3,685 - 0
16.U01 Dea Cease Program $1,900 - 0
11.419 Coastal Zone Management Administration Awards $1,395 - 0
11.035 Broadband Equity, Access, & Deployment Program $1,000 - 0
84.367 Improving Teacher Quality State Grants $311 - 0

Contacts

Name Title Type
DDNMD7YRLX58 Jennifer Messerschmidt Auditee
9204484046 Leah Lasecki Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the County’s 2023 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for ALN 21.019 follow criteria determined by the Department of the Treasury for allowability of costs. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The County has not elected to charge a de minimis indirect cost rate of 10% of modified total direct costs. The accompanying Schedules of Expenditures of Federal and State Awards for Brown County, Wisconsin, are presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the State Single Audit Guidelines issued by the Wisconsin Department of Administration. The Schedules of Expenditures of Federal and State Awards include all federal and state awards of the primary government of Brown County and are not intended to and do not present the financial position, changes in financial position or cash flows of Brown County, Wisconsin. The federal and state awards of the Aging and Disability Resource Center of Brown County, Inc., a component unit of Brown County, is reported in a separate report and is not included in this report.
Title: OVERSIGHT AGENCIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the County’s 2023 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for ALN 21.019 follow criteria determined by the Department of the Treasury for allowability of costs. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The County has not elected to charge a de minimis indirect cost rate of 10% of modified total direct costs. The federal and state oversight agencies for the County are as follows: Federal - U.S. Executive Office of the President State - Wisconsin Department of Health Services
Title: TITLE 19 MEDICAL ASSISTANCE PAYMENTS Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the County’s 2023 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for ALN 21.019 follow criteria determined by the Department of the Treasury for allowability of costs. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The County has not elected to charge a de minimis indirect cost rate of 10% of modified total direct costs. The Schedules of Expenditures of Federal and State Awards do not include revenues of $14,793,232 received by the County for Title 19 Medical Assistance programs. The payments are considered a contract for services between the State and the County and therefore are not reported as federal or state awards. Payments received under the Medicaid Personal Care Program, Wisconsin Medicaid Cost Reporting (WIMCR), Comprehensive Community Services (CCS) Program and Case Management Agency Providers are included in the amount received from the Title 19 Medical Assistance program.
Title: STATE DIRECT PAYMENTS Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the County’s 2023 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Expenditures for ALN 21.019 follow criteria determined by the Department of the Treasury for allowability of costs. Accrued revenue at year-end consists of federal and state program expenditures scheduled for reimbursement to the County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year’s ending balances. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The County has not elected to charge a de minimis indirect cost rate of 10% of modified total direct costs. Payments made directly to recipients and vendors by the State of Wisconsin under the FoodShare Wisconsin program on behalf of the County are not included in the Schedules of Expenditures of Federal and State Awards.

Finding Details

Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.
Finding 2023-002
2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.