Audit 320246

Finding 2023-003 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR section 200.332(a) requires all subaward contracts contain the required information as documented in 2 CFR section 200.332(a)(1) in order for subrecipients to comply with the award agreement. Condition/Context: Both of the two subawards selected for testing did not contain the required elements found in 2 CFR Part 200.332(a). The sample selected was not statistically valid. Cause: The County's subaward agreement template which contains the required elements was not utilized for this program. Effect: The subaward agreement contracts did not contain the required information; therefore, the subrecipients may not have obtained the appropriate grant information needed to comply with the terms and conditions of the award. Questioned Costs: None noted. Recommendation: We recommend utilizing the County's subaward agreement template to ensure the required information is communicated to subrecipients. In addition, the County should consider providing the required information to the subrecipients retrospectively. Management's Response: The County will create Subrecipient Agreements for all providers that are identified as pass-through entities and amend their contracts to add the agreement to existing contracts.

Finding 2023-004 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR Part 200.329(b) and ERA Reporting Guidance requires quarterly reporting to the Treasury portal contain all expenditures and obligations to be clearly identified by type including subawards, contracts, direct payments, or beneficiaries. The required information includes identification of subrecipients which are entities that receive a subaward from a recipient to carry out the purposes (program or project) of the ERA award on behalf of the recipient. Subrecipient relationships require additional monitoring and compliance steps. The direct recipient (the County) is responsible for determining if an entity is considered to be a subrecipient. Condition/Context: Both of the two reports selected for testing contained a contractor that was incorrectly reported as a subaward. Our sample was not statistically valid. Cause: The County did not have internal controls in place requiring an independent person with an understanding of the subrecipient terminology and classification to review the report prior to submission to the U.S. Department of Treasury. Effect: The report was submitted with subrecipient misclassifications. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes in place over completeness and accuracy of reports before submissions to federal agencies are completed. Management's Response: Effective with the 2024 third quarter reporting, the contractor incorrectly reported as a subaward with Treasury was corrected.

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.

Finding 2023-003 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR section 200.332(a) requires all subaward contracts contain the required information as documented in 2 CFR section 200.332(a)(1) in order for subrecipients to comply with the award agreement. Condition/Context: Both of the two subawards selected for testing did not contain the required elements found in 2 CFR Part 200.332(a). The sample selected was not statistically valid. Cause: The County's subaward agreement template which contains the required elements was not utilized for this program. Effect: The subaward agreement contracts did not contain the required information; therefore, the subrecipients may not have obtained the appropriate grant information needed to comply with the terms and conditions of the award. Questioned Costs: None noted. Recommendation: We recommend utilizing the County's subaward agreement template to ensure the required information is communicated to subrecipients. In addition, the County should consider providing the required information to the subrecipients retrospectively. Management's Response: The County will create Subrecipient Agreements for all providers that are identified as pass-through entities and amend their contracts to add the agreement to existing contracts.

Finding 2023-004 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR Part 200.329(b) and ERA Reporting Guidance requires quarterly reporting to the Treasury portal contain all expenditures and obligations to be clearly identified by type including subawards, contracts, direct payments, or beneficiaries. The required information includes identification of subrecipients which are entities that receive a subaward from a recipient to carry out the purposes (program or project) of the ERA award on behalf of the recipient. Subrecipient relationships require additional monitoring and compliance steps. The direct recipient (the County) is responsible for determining if an entity is considered to be a subrecipient. Condition/Context: Both of the two reports selected for testing contained a contractor that was incorrectly reported as a subaward. Our sample was not statistically valid. Cause: The County did not have internal controls in place requiring an independent person with an understanding of the subrecipient terminology and classification to review the report prior to submission to the U.S. Department of Treasury. Effect: The report was submitted with subrecipient misclassifications. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes in place over completeness and accuracy of reports before submissions to federal agencies are completed. Management's Response: Effective with the 2024 third quarter reporting, the contractor incorrectly reported as a subaward with Treasury was corrected.

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.