Federal Agency: U.S. Department of Labor
Federal Program Name: National Farmworker Jobs Program
Assistance Listing Number: 17.264
Federal Award Identification Number and Year: AC-38139-22-60-A-6 - 2023
Award Period: July 01, 2022, through September 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: FFATA reports were not filed for subgrants.
Questioned Costs: None
Context:
Cause: The Department had turnover during the audit period and did not have adequate staffing to know which reports to submit per the grant agreement.
Effect: FFATA reporting was not completed.
Repeat Finding: No
Recommendation: We recommend the County implement policies and procedures to ensure that FFATA reporting occurs for all subawards of $30,000 or more for all federal awards and that the reporting be performed timely.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allocable costs. The County should have internal controls designed to ensure compliance with those provisions. Specifically, § 200.405, Allocable costs, (a) indicates that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: There is an agreement between the Behavioral Health and Recovery Services (BHRS) department and the Adult & Aging (A&A) department whereby the A&A department performs some services for the Mental Health Services (MHS) grant. For these expenditures tested, the initial expenditures were charged to the A&A department and then the portion applicable to the MHS grant is recorded to the MHS program. We were able to review support for the original expenditure to determine the type of expenditures were allowable, yet the County was unable to provide supporting documentation for the amount moved from the A&A department to the MHS grant.
Questioned Costs: $436
Context: This condition was noted on 5 of 16 samples tested. The combined amount of the 5 samples where the condition was noted was $436.
Cause: Documentation for the allocable portion of expenditures could not be located.
Effect: Expenditures recorded to the grant may not be relative to the benefits that were received.
Repeat Finding: No
Recommendation: We recommend the A&A and BHRS departments jointly review its procedures for recorded expenditures being allocated by the A&A department to the MHS grant to ensure that there is documentation supporting the allocation of expenditures and that it is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allocable costs. The County should have internal controls designed to ensure compliance with those provisions. Specifically, § 200.405, Allocable costs, (a) indicates that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: There is an agreement between the Behavioral Health and Recovery Services (BHRS) department and the Adult & Aging (A&A) department whereby the A&A department performs some services for the Mental Health Services (MHS) grant. For these expenditures tested, the initial expenditures were charged to the A&A department and then the portion applicable to the MHS grant is recorded to the MHS program. We were able to review support for the original expenditure to determine the type of expenditures were allowable, yet the County was unable to provide supporting documentation for the amount moved from the A&A department to the MHS grant.
Questioned Costs: $436
Context: This condition was noted on 5 of 16 samples tested. The combined amount of the 5 samples where the condition was noted was $436.
Cause: Documentation for the allocable portion of expenditures could not be located.
Effect: Expenditures recorded to the grant may not be relative to the benefits that were received.
Repeat Finding: No
Recommendation: We recommend the A&A and BHRS departments jointly review its procedures for recorded expenditures being allocated by the A&A department to the MHS grant to ensure that there is documentation supporting the allocation of expenditures and that it is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allocable costs. The County should have internal controls designed to ensure compliance with those provisions. Specifically, § 200.405, Allocable costs, (a) indicates that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: There is an agreement between the Behavioral Health and Recovery Services (BHRS) department and the Adult & Aging (A&A) department whereby the A&A department performs some services for the Mental Health Services (MHS) grant. For these expenditures tested, the initial expenditures were charged to the A&A department and then the portion applicable to the MHS grant is recorded to the MHS program. We were able to review support for the original expenditure to determine the type of expenditures were allowable, yet the County was unable to provide supporting documentation for the amount moved from the A&A department to the MHS grant.
Questioned Costs: $436
Context: This condition was noted on 5 of 16 samples tested. The combined amount of the 5 samples where the condition was noted was $436.
Cause: Documentation for the allocable portion of expenditures could not be located.
Effect: Expenditures recorded to the grant may not be relative to the benefits that were received.
Repeat Finding: No
Recommendation: We recommend the A&A and BHRS departments jointly review its procedures for recorded expenditures being allocated by the A&A department to the MHS grant to ensure that there is documentation supporting the allocation of expenditures and that it is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of compensation for personal services. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: A recalculation of documented hours spent supporting the program, and selected employees' pay rates, resulted in more expenditures being recorded to the program than the amount calculated.
Questioned Costs: $4,317
Context: This condition was noted on 10 of 24 samples tested. The combined difference of the 10 samples where the condition was identified was $4,317.
Cause: The reason for the difference in calculation could not be determined.
Effect: Expenditures recorded to the grant may exceed the relative benefits received from personal services.
Repeat Finding: No
Recommendation: We recommend the County review its process over the allocation of payroll expenditures, based on time worked, to determine what adjustments to its system need to be made.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of compensation for personal services. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: A recalculation of documented hours spent supporting the program, and selected employees' pay rates, resulted in more expenditures being recorded to the program than the amount calculated.
Questioned Costs: $4,317
Context: This condition was noted on 10 of 24 samples tested. The combined difference of the 10 samples where the condition was identified was $4,317.
Cause: The reason for the difference in calculation could not be determined.
Effect: Expenditures recorded to the grant may exceed the relative benefits received from personal services.
Repeat Finding: No
Recommendation: We recommend the County review its process over the allocation of payroll expenditures, based on time worked, to determine what adjustments to its system need to be made.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of compensation for personal services. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: A recalculation of documented hours spent supporting the program, and selected employees' pay rates, resulted in more expenditures being recorded to the program than the amount calculated.
Questioned Costs: $4,317
Context: This condition was noted on 10 of 24 samples tested. The combined difference of the 10 samples where the condition was identified was $4,317.
Cause: The reason for the difference in calculation could not be determined.
Effect: Expenditures recorded to the grant may exceed the relative benefits received from personal services.
Repeat Finding: No
Recommendation: We recommend the County review its process over the allocation of payroll expenditures, based on time worked, to determine what adjustments to its system need to be made.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 4 of 7 samples testing during the first month of the period of performance and 1 of 8 samples tested during the last month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 4 of 7 samples testing during the first month of the period of performance and 1 of 8 samples tested during the last month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 4 of 7 samples testing during the first month of the period of performance and 1 of 8 samples tested during the last month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 3 of 8 samples testing during the first month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Views of Responsible Officials: The County concurs with the finding
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 3 of 8 samples testing during the first month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Views of Responsible Officials: The County concurs with the finding
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 3 of 8 samples testing during the first month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Views of Responsible Officials: The County concurs with the finding
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of direct and indirect costs. The County should have internal controls designed to ensure administrative and other costs that cannot be identified specifically with a particular Federal award as a final cost objective are not recorded as direct costs to the program. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County recorded administrative and other indirect costs as direct costs to the Federal award.
Questioned Costs: Unknown.
Context: For a sample of 60 payroll and nonpayroll expenditures, 5 items tested were indirect costs in nature yet recorded as direct costs.
Cause: The cost allocation program used by the Behavioral Health and Recovery Services (BHRS) department, to allocate costs to various Federal awards and other funding sources, included a blend of expenses that are both direct and indirect in nature as allocated direct costs.
Effect: Indirect costs allocated to the federal award likely exceeded the negotiated indirect cost rate for the award.
Repeat Finding: No
Recommendation: We recommend the County review the cost allocation process of the BHRS department to correctly classify costs between direct and indirect costs.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of direct and indirect costs. The County should have internal controls designed to ensure administrative and other costs that cannot be identified specifically with a particular Federal award as a final cost objective are not recorded as direct costs to the program. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County recorded administrative and other indirect costs as direct costs to the Federal award.
Questioned Costs: Unknown.
Context: For a sample of 60 payroll and nonpayroll expenditures, 5 items tested were indirect costs in nature yet recorded as direct costs.
Cause: The cost allocation program used by the Behavioral Health and Recovery Services (BHRS) department, to allocate costs to various Federal awards and other funding sources, included a blend of expenses that are both direct and indirect in nature as allocated direct costs.
Effect: Indirect costs allocated to the federal award likely exceeded the negotiated indirect cost rate for the award.
Repeat Finding: No
Recommendation: We recommend the County review the cost allocation process of the BHRS department to correctly classify costs between direct and indirect costs.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of direct and indirect costs. The County should have internal controls designed to ensure administrative and other costs that cannot be identified specifically with a particular Federal award as a final cost objective are not recorded as direct costs to the program. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County recorded administrative and other indirect costs as direct costs to the Federal award.
Questioned Costs: Unknown.
Context: For a sample of 60 payroll and nonpayroll expenditures, 5 items tested were indirect costs in nature yet recorded as direct costs.
Cause: The cost allocation program used by the Behavioral Health and Recovery Services (BHRS) department, to allocate costs to various Federal awards and other funding sources, included a blend of expenses that are both direct and indirect in nature as allocated direct costs.
Effect: Indirect costs allocated to the federal award likely exceeded the negotiated indirect cost rate for the award.
Repeat Finding: No
Recommendation: We recommend the County review the cost allocation process of the BHRS department to correctly classify costs between direct and indirect costs.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP0190 - 2021
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: While there was evidence that suspension and debarment verification checks were performed, the County was unable to provide evidence for when the checks were performed to support the fact that they took place prior to the related procurement.
Questioned Costs: None
Context: The condition was noted on 6 of 6 procurement transactions selected for testing.
Cause: Procedures were not in place to retain evidence of when debarment status checks took place.
Effect: The County is unable to prove that internal control procedures over suspension and debarment compliance were performed in a timely manner.
Repeat Finding: No
Recommendation: We recommend that the County add a section to its standard contractor and subrecipient contracts for the other party to certify they are not suspended or debarred. In addition, we recommend the County establish controls to ensure that evidence of suspension and debarment compliance procedures is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Labor
Federal Program Name: National Farmworker Jobs Program
Assistance Listing Number: 17.264
Federal Award Identification Number and Year: AC-38139-22-60-A-6 - 2023
Award Period: July 01, 2022, through September 30, 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: FFATA reports were not filed for subgrants.
Questioned Costs: None
Context:
Cause: The Department had turnover during the audit period and did not have adequate staffing to know which reports to submit per the grant agreement.
Effect: FFATA reporting was not completed.
Repeat Finding: No
Recommendation: We recommend the County implement policies and procedures to ensure that FFATA reporting occurs for all subawards of $30,000 or more for all federal awards and that the reporting be performed timely.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allocable costs. The County should have internal controls designed to ensure compliance with those provisions. Specifically, § 200.405, Allocable costs, (a) indicates that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: There is an agreement between the Behavioral Health and Recovery Services (BHRS) department and the Adult & Aging (A&A) department whereby the A&A department performs some services for the Mental Health Services (MHS) grant. For these expenditures tested, the initial expenditures were charged to the A&A department and then the portion applicable to the MHS grant is recorded to the MHS program. We were able to review support for the original expenditure to determine the type of expenditures were allowable, yet the County was unable to provide supporting documentation for the amount moved from the A&A department to the MHS grant.
Questioned Costs: $436
Context: This condition was noted on 5 of 16 samples tested. The combined amount of the 5 samples where the condition was noted was $436.
Cause: Documentation for the allocable portion of expenditures could not be located.
Effect: Expenditures recorded to the grant may not be relative to the benefits that were received.
Repeat Finding: No
Recommendation: We recommend the A&A and BHRS departments jointly review its procedures for recorded expenditures being allocated by the A&A department to the MHS grant to ensure that there is documentation supporting the allocation of expenditures and that it is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allocable costs. The County should have internal controls designed to ensure compliance with those provisions. Specifically, § 200.405, Allocable costs, (a) indicates that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: There is an agreement between the Behavioral Health and Recovery Services (BHRS) department and the Adult & Aging (A&A) department whereby the A&A department performs some services for the Mental Health Services (MHS) grant. For these expenditures tested, the initial expenditures were charged to the A&A department and then the portion applicable to the MHS grant is recorded to the MHS program. We were able to review support for the original expenditure to determine the type of expenditures were allowable, yet the County was unable to provide supporting documentation for the amount moved from the A&A department to the MHS grant.
Questioned Costs: $436
Context: This condition was noted on 5 of 16 samples tested. The combined amount of the 5 samples where the condition was noted was $436.
Cause: Documentation for the allocable portion of expenditures could not be located.
Effect: Expenditures recorded to the grant may not be relative to the benefits that were received.
Repeat Finding: No
Recommendation: We recommend the A&A and BHRS departments jointly review its procedures for recorded expenditures being allocated by the A&A department to the MHS grant to ensure that there is documentation supporting the allocation of expenditures and that it is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of allocable costs. The County should have internal controls designed to ensure compliance with those provisions. Specifically, § 200.405, Allocable costs, (a) indicates that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: There is an agreement between the Behavioral Health and Recovery Services (BHRS) department and the Adult & Aging (A&A) department whereby the A&A department performs some services for the Mental Health Services (MHS) grant. For these expenditures tested, the initial expenditures were charged to the A&A department and then the portion applicable to the MHS grant is recorded to the MHS program. We were able to review support for the original expenditure to determine the type of expenditures were allowable, yet the County was unable to provide supporting documentation for the amount moved from the A&A department to the MHS grant.
Questioned Costs: $436
Context: This condition was noted on 5 of 16 samples tested. The combined amount of the 5 samples where the condition was noted was $436.
Cause: Documentation for the allocable portion of expenditures could not be located.
Effect: Expenditures recorded to the grant may not be relative to the benefits that were received.
Repeat Finding: No
Recommendation: We recommend the A&A and BHRS departments jointly review its procedures for recorded expenditures being allocated by the A&A department to the MHS grant to ensure that there is documentation supporting the allocation of expenditures and that it is retained.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of compensation for personal services. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: A recalculation of documented hours spent supporting the program, and selected employees' pay rates, resulted in more expenditures being recorded to the program than the amount calculated.
Questioned Costs: $4,317
Context: This condition was noted on 10 of 24 samples tested. The combined difference of the 10 samples where the condition was identified was $4,317.
Cause: The reason for the difference in calculation could not be determined.
Effect: Expenditures recorded to the grant may exceed the relative benefits received from personal services.
Repeat Finding: No
Recommendation: We recommend the County review its process over the allocation of payroll expenditures, based on time worked, to determine what adjustments to its system need to be made.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of compensation for personal services. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: A recalculation of documented hours spent supporting the program, and selected employees' pay rates, resulted in more expenditures being recorded to the program than the amount calculated.
Questioned Costs: $4,317
Context: This condition was noted on 10 of 24 samples tested. The combined difference of the 10 samples where the condition was identified was $4,317.
Cause: The reason for the difference in calculation could not be determined.
Effect: Expenditures recorded to the grant may exceed the relative benefits received from personal services.
Repeat Finding: No
Recommendation: We recommend the County review its process over the allocation of payroll expenditures, based on time worked, to determine what adjustments to its system need to be made.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: COVID-19 Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of compensation for personal services. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: A recalculation of documented hours spent supporting the program, and selected employees' pay rates, resulted in more expenditures being recorded to the program than the amount calculated.
Questioned Costs: $4,317
Context: This condition was noted on 10 of 24 samples tested. The combined difference of the 10 samples where the condition was identified was $4,317.
Cause: The reason for the difference in calculation could not be determined.
Effect: Expenditures recorded to the grant may exceed the relative benefits received from personal services.
Repeat Finding: No
Recommendation: We recommend the County review its process over the allocation of payroll expenditures, based on time worked, to determine what adjustments to its system need to be made.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 4 of 7 samples testing during the first month of the period of performance and 1 of 8 samples tested during the last month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 4 of 7 samples testing during the first month of the period of performance and 1 of 8 samples tested during the last month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Community Mental Health Services
Assistance Listing Number: 93.958
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 4 of 7 samples testing during the first month of the period of performance and 1 of 8 samples tested during the last month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 3 of 8 samples testing during the first month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Views of Responsible Officials: The County concurs with the finding
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 3 of 8 samples testing during the first month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Views of Responsible Officials: The County concurs with the finding
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of period of performance. The County should have internal controls designed to ensure that expenditures are recorded within the period of performance. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County incorrectly included a portion of nonpayroll costs which were predominantly incurred before or after the period of performance.
Questioned Costs: None.
Context: This condition was on 3 of 8 samples testing during the first month of the period of performance.
Cause: The compilation of expenditures reported was based on the system date for when expenditures were recorded in the system instead of when benefits from the expenditures were received.
Effect: Expenditures recorded to the grant may have been recorded outside of the grant’s period of performance.
Repeat Finding: No
Recommendation: We recommend the County conduct training with its various departments to instruct them on how to compile expenditures based on the accrual basis of accounting (when the benefits from the expenditures were received).
Views of Responsible Officials: The County concurs with the finding
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of direct and indirect costs. The County should have internal controls designed to ensure administrative and other costs that cannot be identified specifically with a particular Federal award as a final cost objective are not recorded as direct costs to the program. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County recorded administrative and other indirect costs as direct costs to the Federal award.
Questioned Costs: Unknown.
Context: For a sample of 60 payroll and nonpayroll expenditures, 5 items tested were indirect costs in nature yet recorded as direct costs.
Cause: The cost allocation program used by the Behavioral Health and Recovery Services (BHRS) department, to allocate costs to various Federal awards and other funding sources, included a blend of expenses that are both direct and indirect in nature as allocated direct costs.
Effect: Indirect costs allocated to the federal award likely exceeded the negotiated indirect cost rate for the award.
Repeat Finding: No
Recommendation: We recommend the County review the cost allocation process of the BHRS department to correctly classify costs between direct and indirect costs.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of direct and indirect costs. The County should have internal controls designed to ensure administrative and other costs that cannot be identified specifically with a particular Federal award as a final cost objective are not recorded as direct costs to the program. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County recorded administrative and other indirect costs as direct costs to the Federal award.
Questioned Costs: Unknown.
Context: For a sample of 60 payroll and nonpayroll expenditures, 5 items tested were indirect costs in nature yet recorded as direct costs.
Cause: The cost allocation program used by the Behavioral Health and Recovery Services (BHRS) department, to allocate costs to various Federal awards and other funding sources, included a blend of expenses that are both direct and indirect in nature as allocated direct costs.
Effect: Indirect costs allocated to the federal award likely exceeded the negotiated indirect cost rate for the award.
Repeat Finding: No
Recommendation: We recommend the County review the cost allocation process of the BHRS department to correctly classify costs between direct and indirect costs.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Health and Human Services
Federal Program Name: Block Grants for Prevention and Treatment of Substance Abuse
Assistance Listing Number: 93.959
Pass-Through Agency: California Department of Health Care Services
Award Period: July 01, 2022, through June 2023
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of direct and indirect costs. The County should have internal controls designed to ensure administrative and other costs that cannot be identified specifically with a particular Federal award as a final cost objective are not recorded as direct costs to the program. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: During our testing of Allowable Costs, we noted that the County recorded administrative and other indirect costs as direct costs to the Federal award.
Questioned Costs: Unknown.
Context: For a sample of 60 payroll and nonpayroll expenditures, 5 items tested were indirect costs in nature yet recorded as direct costs.
Cause: The cost allocation program used by the Behavioral Health and Recovery Services (BHRS) department, to allocate costs to various Federal awards and other funding sources, included a blend of expenses that are both direct and indirect in nature as allocated direct costs.
Effect: Indirect costs allocated to the federal award likely exceeded the negotiated indirect cost rate for the award.
Repeat Finding: No
Recommendation: We recommend the County review the cost allocation process of the BHRS department to correctly classify costs between direct and indirect costs.
Views of Responsible Officials: The County concurs with the finding.
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: SLFRP0190 - 2021
Award Period: July 01, 2022, through June 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires compliance with the provisions of procurement, suspension, and debarment. The County should have internal controls designed to ensure compliance with those provisions. Additionally, 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award section 200.303 requires that entities 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).
Condition: While there was evidence that suspension and debarment verification checks were performed, the County was unable to provide evidence for when the checks were performed to support the fact that they took place prior to the related procurement.
Questioned Costs: None
Context: The condition was noted on 6 of 6 procurement transactions selected for testing.
Cause: Procedures were not in place to retain evidence of when debarment status checks took place.
Effect: The County is unable to prove that internal control procedures over suspension and debarment compliance were performed in a timely manner.
Repeat Finding: No
Recommendation: We recommend that the County add a section to its standard contractor and subrecipient contracts for the other party to certify they are not suspended or debarred. In addition, we recommend the County establish controls to ensure that evidence of suspension and debarment compliance procedures is retained.
Views of Responsible Officials: The County concurs with the finding.