2023-003 Procurement Policy
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Transportation
Program: 20.205 Highway Planning and Construction
Award Number and Year: 1052063; 2023
Pass-Through Agency: Minnesota Department of Transportation
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Title 2 U.S. Code of Federal Regulations § 200.318 states that the non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform with applicable federal law and the standards identified in this regulation.
Condition: Traverse County has written procurement policies; however, these policies do not include the required components in accordance with Title 2 U.S. Code of Federal Regulations §200.318.
Questioned Costs: None
Context: This issue was discovered during the audit of the major federal program; however, it impacts federal programs entity-wide. Written policies that reflect the specific components of federal regulations improve controls to ensure compliance with federal award requirements.
Effect: Written policies and procedures that are not updated to reflect the federal procurement requirements could increase the risk of noncompliance with federal program requirements.
Cause: Traverse County management was unaware the procurement policy did not include all the requirements.
Recommendation: We recommend Traverse County include the specific components of the Uniform Guidance requirements in its written procurement policies and procedures.
View of Responsible Official: Acknowledge
2023-004 Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Material Weakness and Modified Opinion
Federal Agency: U.S. Department of Health and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Administrative program costs for Medical Assistance Program are submitted to the Minnesota Department of
Human Services (DHS) through the DHS Income Maintenance (DHS-2550) report and the Social Service Fund (DHS-2556) report on a quarterly basis. DHS provides reporting instructions including information regarding eligible and ineligible costs.
Condition: The following exceptions were noted in the sample of 40 expenditures tested for activities allowed or unallowed and allowable costs/cost principles:
• Three claims were included in the DHS-2550 and DHS-2556 reports as eligible expenditures but were not eligible for federal reimbursement.
• For eleven timesheets tested, the payroll costs were allocated on an incorrect full-time equivalent (FTE) split, as the income maintenance and social services splits had been entered into the system inversely.
Questioned Costs: Questioned costs identified were less than $25,000.
Context: DHS relies on accurate identification and reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs.
The sample sizes were based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Errors in the identification and reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity.
Cause: The County’s controls over the identification of allowable activities and costs, preparation of the quarterly reports, and maintenance of payroll allocations in the accounting system were not sufficient to identify these errors.
Recommendation: We recommend the County implement controls to ensure activities allowed and allowable costs are appropriately identified and accurately reported to DHS in accordance with federal program guidance and DHS instructions. We also recommend reports submitted with unallowable activities or costs, costs allocated incorrectly, or activity reported incorrectly are corrected and resubmitted.
View of Responsible Official: Acknowledge
2023-005 Reporting (DHS 2550 and 2556)
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Material Weakness and Modified Opinion
Federal Agency: U.S. Department of Heath and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Administrative program costs for Medical Assistance Program are submitted to the Minnesota Department of Human Services (DHS) through the DHS Income Maintenance (DHS-2550) report and the Social Service Fund (DHS-2556) report on a quarterly basis. DHS provides reporting instructions, including information regarding eligible and ineligible costs.
Condition: The following exceptions were noted in a sample of quarterly reports tested:
• In the DHS-2550 second and fourth quarter reports, salary reimbursements were reported as a reduction to income maintenance administrative overhead expenditures for “Salary and Fringe” and “Services and Charges” rather than as “Revenue Offset.” In the DHS-2556 second and fourth quarter reports, salary reimbursements were reported as reductions in payroll expenditures rather than miscellaneous revenue.
• The social services department does not have a rental agreement in place to support the rent payments included in both the DHS-2550 and DHS-2556 second and fourth quarter reports.
• In the DHS-2556 second quarter report, revenue was reported as Fees for Services rather than Intergovernmental Federal Revenue.
• In both the DHS-2550 and DHS-2556 fourth quarter reports, expenditures were reported related to remodeling areas not used exclusively for income maintenance or social service programs instead of only reporting these areas' proportionate share of costs.
Questioned Costs: Questioned costs identified were less than $25,000.
Context: DHS relies on accurate identification and reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs.
The sample sizes were based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Errors in the reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity.
Cause: The County’s controls over preparation of the quarterly reports were not sufficient to identify the reporting errors.
Recommendation: We recommend Traverse County implement controls to ensure accurate reporting to DHS in accordance with federal program guidance and DHS instructions. We also recommend reports submitted incorrectly are corrected and resubmitted.
View of Responsible Official: Acknowledge
2023-006 Local Collaborative Time Study (LCTS) Reporting (Cost Schedules DHS-3220.2)
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
For federal awards received from the Minnesota Department of Human Services (DHS), the County should establish and maintain internal control to provide assurance that program reports submitted to DHS are completed in accordance with reporting instructions. As part of Traverse County’s reporting requirements, the County submits the Local Collaborative Time Study (LCTS) Corrections Cost Schedules DHS-3220.2 on a quarterly basis.
Condition: The following exceptions were noted in the sample of the Corrections Cost Schedules DHS-3220.2 tested:
• The County reported rent payments in the second and fourth quarters, but the County paid the rent in the third quarter of 2023 and the first quarter of 2024, respectively.
• Reported direct labor and benefit expenditures in the second and fourth quarters were estimated based on a portion of the individuals’ annual salary rather than actual salaries and benefits in the general ledger.
• The County reported only 27 percent of expenditures incurred in the second quarter and 30 percent of expenditures incurred in the fourth quarter.
Questioned Costs: None
Context: DHS relies on accurate reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs. Revised reports have since been submitted by the County to correct for the errors identified in the audit.
The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Errors in the reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity.
Cause: County staff indicated errors were due to lack of oversight and detailed review of costs being included or excluded from the quarterly reports submitted to DHS.
Recommendation: We recommend Traverse County implement detailed supervisory review procedures to ensure accurate reporting to DHS in accordance with federal program guidance and DHS instructions.
View of Responsible Official: Acknowledge
2023-007 Local Collaborative Time Study (LCTS) Reporting (Cost Schedules DHS-3220.1 and DHS-3220.2)
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
As part of Traverse County’s Local Collaborative Time Study (LCTS) reporting requirements for Schools (DHS-3220.1) and Corrections (DHS-3220.2), LCTS fiscal site contacts are required to verify that the information on the LCTS Fiscal and Cost Schedule is accurate and that it complies with all guidelines set forth in the LCTS Cost Schedule Instructions described in DHS Bulletin #16-32-04 – Local Collaborative Time Study (LCTS) Fiscal Operations. It also states that the County’s LCTS Fiscal Reporting and Payment Agent is required to review all cost schedules from participating agencies.
Condition: No documentation was maintained to support that the two Cost Schedules DHS-3220.1 and the two Cost Schedules DHS-3220.2 tested in the sample were reviewed by the County’s LCTS Fiscal Reporting and Payment Agent.
Questioned Costs: None
Context: The Cost Schedules DHS-3220 are submitted quarterly by each member of a collaborative to DHS for reimbursement of LCTS money, which is reimbursed to the County with federal Medical Assistance Program funds. The Traverse County Social Services Department acts as the LCTS Fiscal Reporting and Payment Agent for the local collaborative in Traverse County.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Lack of a review process increases the risk that reports reports will not be submitted as required or accurate.
Cause: Staff from the County’s Social Services Department indicated they were not aware of the review requirements for the quarterly reports.
Recommendation: We recommend the County implement procedures to ensure the cost schedules are reviewed and evidence of the review is retained.
View of Responsible Official: Acknowledge
2023-003 Procurement Policy
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Transportation
Program: 20.205 Highway Planning and Construction
Award Number and Year: 1052063; 2023
Pass-Through Agency: Minnesota Department of Transportation
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Title 2 U.S. Code of Federal Regulations § 200.318 states that the non-federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurements conform with applicable federal law and the standards identified in this regulation.
Condition: Traverse County has written procurement policies; however, these policies do not include the required components in accordance with Title 2 U.S. Code of Federal Regulations §200.318.
Questioned Costs: None
Context: This issue was discovered during the audit of the major federal program; however, it impacts federal programs entity-wide. Written policies that reflect the specific components of federal regulations improve controls to ensure compliance with federal award requirements.
Effect: Written policies and procedures that are not updated to reflect the federal procurement requirements could increase the risk of noncompliance with federal program requirements.
Cause: Traverse County management was unaware the procurement policy did not include all the requirements.
Recommendation: We recommend Traverse County include the specific components of the Uniform Guidance requirements in its written procurement policies and procedures.
View of Responsible Official: Acknowledge
2023-004 Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Material Weakness and Modified Opinion
Federal Agency: U.S. Department of Health and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Administrative program costs for Medical Assistance Program are submitted to the Minnesota Department of
Human Services (DHS) through the DHS Income Maintenance (DHS-2550) report and the Social Service Fund (DHS-2556) report on a quarterly basis. DHS provides reporting instructions including information regarding eligible and ineligible costs.
Condition: The following exceptions were noted in the sample of 40 expenditures tested for activities allowed or unallowed and allowable costs/cost principles:
• Three claims were included in the DHS-2550 and DHS-2556 reports as eligible expenditures but were not eligible for federal reimbursement.
• For eleven timesheets tested, the payroll costs were allocated on an incorrect full-time equivalent (FTE) split, as the income maintenance and social services splits had been entered into the system inversely.
Questioned Costs: Questioned costs identified were less than $25,000.
Context: DHS relies on accurate identification and reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs.
The sample sizes were based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Errors in the identification and reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity.
Cause: The County’s controls over the identification of allowable activities and costs, preparation of the quarterly reports, and maintenance of payroll allocations in the accounting system were not sufficient to identify these errors.
Recommendation: We recommend the County implement controls to ensure activities allowed and allowable costs are appropriately identified and accurately reported to DHS in accordance with federal program guidance and DHS instructions. We also recommend reports submitted with unallowable activities or costs, costs allocated incorrectly, or activity reported incorrectly are corrected and resubmitted.
View of Responsible Official: Acknowledge
2023-005 Reporting (DHS 2550 and 2556)
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Material Weakness and Modified Opinion
Federal Agency: U.S. Department of Heath and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Administrative program costs for Medical Assistance Program are submitted to the Minnesota Department of Human Services (DHS) through the DHS Income Maintenance (DHS-2550) report and the Social Service Fund (DHS-2556) report on a quarterly basis. DHS provides reporting instructions, including information regarding eligible and ineligible costs.
Condition: The following exceptions were noted in a sample of quarterly reports tested:
• In the DHS-2550 second and fourth quarter reports, salary reimbursements were reported as a reduction to income maintenance administrative overhead expenditures for “Salary and Fringe” and “Services and Charges” rather than as “Revenue Offset.” In the DHS-2556 second and fourth quarter reports, salary reimbursements were reported as reductions in payroll expenditures rather than miscellaneous revenue.
• The social services department does not have a rental agreement in place to support the rent payments included in both the DHS-2550 and DHS-2556 second and fourth quarter reports.
• In the DHS-2556 second quarter report, revenue was reported as Fees for Services rather than Intergovernmental Federal Revenue.
• In both the DHS-2550 and DHS-2556 fourth quarter reports, expenditures were reported related to remodeling areas not used exclusively for income maintenance or social service programs instead of only reporting these areas' proportionate share of costs.
Questioned Costs: Questioned costs identified were less than $25,000.
Context: DHS relies on accurate identification and reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs.
The sample sizes were based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Errors in the reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity.
Cause: The County’s controls over preparation of the quarterly reports were not sufficient to identify the reporting errors.
Recommendation: We recommend Traverse County implement controls to ensure accurate reporting to DHS in accordance with federal program guidance and DHS instructions. We also recommend reports submitted incorrectly are corrected and resubmitted.
View of Responsible Official: Acknowledge
2023-006 Local Collaborative Time Study (LCTS) Reporting (Cost Schedules DHS-3220.2)
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
For federal awards received from the Minnesota Department of Human Services (DHS), the County should establish and maintain internal control to provide assurance that program reports submitted to DHS are completed in accordance with reporting instructions. As part of Traverse County’s reporting requirements, the County submits the Local Collaborative Time Study (LCTS) Corrections Cost Schedules DHS-3220.2 on a quarterly basis.
Condition: The following exceptions were noted in the sample of the Corrections Cost Schedules DHS-3220.2 tested:
• The County reported rent payments in the second and fourth quarters, but the County paid the rent in the third quarter of 2023 and the first quarter of 2024, respectively.
• Reported direct labor and benefit expenditures in the second and fourth quarters were estimated based on a portion of the individuals’ annual salary rather than actual salaries and benefits in the general ledger.
• The County reported only 27 percent of expenditures incurred in the second quarter and 30 percent of expenditures incurred in the fourth quarter.
Questioned Costs: None
Context: DHS relies on accurate reporting of program costs to ensure grant funds paid to the County are for allowable federal program activities/costs and provide detailed information necessary for maintaining proper oversight over federal programs. Revised reports have since been submitted by the County to correct for the errors identified in the audit.
The sample size was based on the guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Errors in the reporting of costs on the quarterly reports can impair the ability of DHS to provide required oversight over federal programs and result in the County receiving either more or less federal funds than justified based on the actual underlying activity.
Cause: County staff indicated errors were due to lack of oversight and detailed review of costs being included or excluded from the quarterly reports submitted to DHS.
Recommendation: We recommend Traverse County implement detailed supervisory review procedures to ensure accurate reporting to DHS in accordance with federal program guidance and DHS instructions.
View of Responsible Official: Acknowledge
2023-007 Local Collaborative Time Study (LCTS) Reporting (Cost Schedules DHS-3220.1 and DHS-3220.2)
Prior Year Finding Number: N/A
Year of Finding Origination: 2023
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Program: 93.778 Medical Assistance Program
Award Number and Year: 2305MN5ADM, 2023
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
As part of Traverse County’s Local Collaborative Time Study (LCTS) reporting requirements for Schools (DHS-3220.1) and Corrections (DHS-3220.2), LCTS fiscal site contacts are required to verify that the information on the LCTS Fiscal and Cost Schedule is accurate and that it complies with all guidelines set forth in the LCTS Cost Schedule Instructions described in DHS Bulletin #16-32-04 – Local Collaborative Time Study (LCTS) Fiscal Operations. It also states that the County’s LCTS Fiscal Reporting and Payment Agent is required to review all cost schedules from participating agencies.
Condition: No documentation was maintained to support that the two Cost Schedules DHS-3220.1 and the two Cost Schedules DHS-3220.2 tested in the sample were reviewed by the County’s LCTS Fiscal Reporting and Payment Agent.
Questioned Costs: None
Context: The Cost Schedules DHS-3220 are submitted quarterly by each member of a collaborative to DHS for reimbursement of LCTS money, which is reimbursed to the County with federal Medical Assistance Program funds. The Traverse County Social Services Department acts as the LCTS Fiscal Reporting and Payment Agent for the local collaborative in Traverse County.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Lack of a review process increases the risk that reports reports will not be submitted as required or accurate.
Cause: Staff from the County’s Social Services Department indicated they were not aware of the review requirements for the quarterly reports.
Recommendation: We recommend the County implement procedures to ensure the cost schedules are reviewed and evidence of the review is retained.
View of Responsible Official: Acknowledge