Audit 320852

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-003 Review of Claim Forms and Expenditure Reconciliations Federal Agency: Department of Health and Human Services Federal Program Name: Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program Assistance Listing Number: 93.778 / 93.324 / 93.071 Federal Award Identification Number and Year: N/A Pass-Through Agency: WI DHS Pass-Through Number(s): 560100 / 560152 / 560155 / 560320 / 560328 / 560432 / 560620 Award Period: January 1, 2023 through December 31, 2023 Type of Finding: Significant deficiency in internal control over compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The State single audit guidelines require the County to perform control activities for ensuring accurate reporting, such as timely and accurate reconciliations. Monthly review of financial information, including claim forms and reconciliations, are an important control over compliance to ensure expenditure reimbursements are properly prepared and agree with the County's actual activity. Condition The County did not perform review procedures over claims prior to submission. Questioned Costs None Context During our testing, it was noted on all three reports tested that Florence County was not reviewing claims prior to submission. Effect Unallowed costs could be claimed, or costs could be double claimed. Cause While monthly claims were being prepared and reconciled to the ledger, there was no review over those claims prior to submission. Repeat Finding The finding is not a repeat finding in the immediately prior year. Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-003 (Continued) Recommendation We recommend the County designate an individual to obtain additional training in order to review each grant claim. In addition, we recommend the county consider developing a financial policies and procedures manual to document and assist in completing the claims process. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and has developed a plan to correct the finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.