FINDING 2023-002
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY2023
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2022-001.
INDIANA STATE BOARD OF ACCOUNTS
14
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
The County elected to receive the standard revenue loss allowance, allowing the County to claim
its total State and Local Fiscal Recovery Funds (SLFRF) allocation of $9,500,777 as revenue loss to use
for government services. As such, all SLFRF program funds during the audit period were expended under
the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that
there are no subawards under this eligible use category, and that recipients' use of revenue loss funds
would not give rise to subrecipient relationships given that there is no federal program or purpose to carry
out in the case of the revenue loss portion of the award.
Prior to entering into subawards and covered transactions with SLFRF funds, recipients are
required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise
excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded
under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000.
The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification
from that person, or adding a clause or condition to the covered transaction with that person. Due to the
Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the
County was only required to comply with suspension and debarment requirements related to covered
transactions.
Upon inquiry of the County to review the procedures in place for verifying that an entity with which
it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified
from participating in federal assistance programs or activities, the County divulged they had no process in
place during the audit period. Of the 13 total covered transactions for goods or services paid from the
SLFRF program funds during the audit period, 3 transactions were selected for testing. Due to the County
not having policies or procedures in place to verify the vendor's suspension or debarment status, the County
did not verify any of the 3 vendors' statuses prior to payment.
The lack of internal controls and noncompliance were a systemic issue throughout the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
31 CFR 19.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
INDIANA STATE BOARD OF ACCOUNTS
15
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
(a) Checking the EPLS; or
(b) Collecting a certification from that person if allowed by this rule; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
A proper system of internal controls was not designed by management of the County. Embedded
within a properly designed and implemented internal control system should be internal controls consisting
of policies and procedures. Policies reflect the County's management statements of what should be done
to effect internal controls, and procedures should consist of actions that would implement these policies.
Effect
Without the proper implementation of an effectively designed system of internal controls, the
internal control system cannot be capable of effectively preventing, or detecting and correcting, material
noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were made were
not verified to be not suspended, debarred, or otherwise excluded. Any program funds the County used to
pay contractors that have been suspended or debarred would be unallowable, and the funding agency
could potentially recover them.
Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of
the federal award could result in the loss of future federal funding to the County.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County establish a proper system of internal controls
and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not
suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY2023
Compliance Requirement: Reporting
Audit Finding: Significant Deficiency
INDIANA STATE BOARD OF ACCOUNTS 16
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2022-002.
Condition and Context
The County had not established an effective system of internal controls that would likely be effective
in preventing, or detecting and correcting, noncompliance. Recipients are required to submit quarterly or
annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The
reporting periods, as well as the respective due dates are based upon type of recipient and its population,
as well as the recipient's allocation amount. Information to be reported includes projects funded,
expenditures, and contracts for the appropriate reporting period.
The County was classified as a county with a population below 250,000 residents that received an
allocation of less than $10 million in State and Local Fiscal Recovery Funds funding. As such, the initial
P&E report, covering the period from March 3, 2021 to March 31, 2022, was required to be submitted to
the Treasury by April 30, 2022. The subsequent annual reports are to cover one calendar year and must
be submitted to the Treasury by April 30 each year.
The County submitted one P&E report during the audit period. The Chief Deputy County Auditor
was responsible for preparing and submitting the P&E report, and the County Auditor reviewed and
approved the report prior to submission; however, there was no documentation that suggested that this
review process was in place that could be provided.
The lack of internal controls was systemic throughout the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
Cause
A proper system of internal controls over the P&E report was not designed by management of the
County. Embedded within a properly designed and implemented internal control system should be internal
controls consisting of policies and procedures. Policies reflect the County's management statements of
what should be done to effect internal controls, and procedures should consist of actions that would
implement these policies.
INDIANA STATE BOARD OF ACCOUNTS
17
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
Without the proper implementation of an effectively designed system of internal controls, the
internal control system cannot be capable of effectively preventing, or detecting and correcting, material
noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and
conditions of the federal award could result in the loss of future federal funding to the County.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the County's management design and implement a proper system of
internal controls. In addition, we recommended that review processes and procedures by documented and
retained for audit.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY2023
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2022-001.
INDIANA STATE BOARD OF ACCOUNTS
14
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Condition and Context
The County elected to receive the standard revenue loss allowance, allowing the County to claim
its total State and Local Fiscal Recovery Funds (SLFRF) allocation of $9,500,777 as revenue loss to use
for government services. As such, all SLFRF program funds during the audit period were expended under
the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that
there are no subawards under this eligible use category, and that recipients' use of revenue loss funds
would not give rise to subrecipient relationships given that there is no federal program or purpose to carry
out in the case of the revenue loss portion of the award.
Prior to entering into subawards and covered transactions with SLFRF funds, recipients are
required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise
excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded
under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000.
The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification
from that person, or adding a clause or condition to the covered transaction with that person. Due to the
Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the
County was only required to comply with suspension and debarment requirements related to covered
transactions.
Upon inquiry of the County to review the procedures in place for verifying that an entity with which
it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified
from participating in federal assistance programs or activities, the County divulged they had no process in
place during the audit period. Of the 13 total covered transactions for goods or services paid from the
SLFRF program funds during the audit period, 3 transactions were selected for testing. Due to the County
not having policies or procedures in place to verify the vendor's suspension or debarment status, the County
did not verify any of the 3 vendors' statuses prior to payment.
The lack of internal controls and noncompliance were a systemic issue throughout the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
31 CFR 19.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you intend to do business is not excluded or disqualified. You
do this by:
INDIANA STATE BOARD OF ACCOUNTS
15
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
(a) Checking the EPLS; or
(b) Collecting a certification from that person if allowed by this rule; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
A proper system of internal controls was not designed by management of the County. Embedded
within a properly designed and implemented internal control system should be internal controls consisting
of policies and procedures. Policies reflect the County's management statements of what should be done
to effect internal controls, and procedures should consist of actions that would implement these policies.
Effect
Without the proper implementation of an effectively designed system of internal controls, the
internal control system cannot be capable of effectively preventing, or detecting and correcting, material
noncompliance. As a result, vendors to whom payments equal to or in excess of $25,000 were made were
not verified to be not suspended, debarred, or otherwise excluded. Any program funds the County used to
pay contractors that have been suspended or debarred would be unallowable, and the funding agency
could potentially recover them.
Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of
the federal award could result in the loss of future federal funding to the County.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County establish a proper system of internal controls
and develop policies and procedures to ensure contractors and subrecipients, as appropriate, are not
suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY2023
Compliance Requirement: Reporting
Audit Finding: Significant Deficiency
INDIANA STATE BOARD OF ACCOUNTS 16
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2022-002.
Condition and Context
The County had not established an effective system of internal controls that would likely be effective
in preventing, or detecting and correcting, noncompliance. Recipients are required to submit quarterly or
annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The
reporting periods, as well as the respective due dates are based upon type of recipient and its population,
as well as the recipient's allocation amount. Information to be reported includes projects funded,
expenditures, and contracts for the appropriate reporting period.
The County was classified as a county with a population below 250,000 residents that received an
allocation of less than $10 million in State and Local Fiscal Recovery Funds funding. As such, the initial
P&E report, covering the period from March 3, 2021 to March 31, 2022, was required to be submitted to
the Treasury by April 30, 2022. The subsequent annual reports are to cover one calendar year and must
be submitted to the Treasury by April 30 each year.
The County submitted one P&E report during the audit period. The Chief Deputy County Auditor
was responsible for preparing and submitting the P&E report, and the County Auditor reviewed and
approved the report prior to submission; however, there was no documentation that suggested that this
review process was in place that could be provided.
The lack of internal controls was systemic throughout the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in
compliance with Federal statutes, regulations, and the terms and conditions of the Federal
award. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
Cause
A proper system of internal controls over the P&E report was not designed by management of the
County. Embedded within a properly designed and implemented internal control system should be internal
controls consisting of policies and procedures. Policies reflect the County's management statements of
what should be done to effect internal controls, and procedures should consist of actions that would
implement these policies.
INDIANA STATE BOARD OF ACCOUNTS
17
HENRY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
Without the proper implementation of an effectively designed system of internal controls, the
internal control system cannot be capable of effectively preventing, or detecting and correcting, material
noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and
conditions of the federal award could result in the loss of future federal funding to the County.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that the County's management design and implement a proper system of
internal controls. In addition, we recommended that review processes and procedures by documented and
retained for audit.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.