Audit 325007

Criteria: The Uniform Guidance and the State and Local Fiscal Recovery Funds (SLFRF) Program notes that recipients may use SLFRF payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 codified at 42 USC sections 802 and 803, respectively. Recipients may also use payments subject to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35. Condition: During our testing of the SLFRF Program of the County, we noted two (2) instances where approval control procedures related to the allowable cost compliance requirement were not performed. Context: We addressed these matters with County management who are aware of the allowable cost requirements and the related controls. Effect: Failure to follow internal controls related to allowable costs can lead to noncompliance and spending federal funds on ineligible goods or services or other uses. Cause: Management oversight. Recommendation: We recommend the County review and update its policies and procedures to ensure all internal controls are being followed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program. Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The County is in the process of implementing controls and procedures to ensure all internal control procedures are being performed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program.

Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and/or subrecipients are not suspended, debarred, or otherwise excluded pursuant to the Uniform Guidance. Condition: During our testing of the SLFRF Program of the County, we noted two (2) instances where suspension and debarment was not checked before vendor procurement was completed. Context: We addressed these matters with County management who are aware of the procurement suspension and debarment requirements. Effect: Failure to verify suspension and debarment can lead to noncompliance and procuring with an ineligible vendor. Cause: Management oversight. Recommendation: We recommend the County review and update its policies and procedures to ensure all suspension and debarment procedures are being performed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program. Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The County is in the process of implementing controls and procedures to ensure suspension and debarment procedures are being performed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program.

Criteria: The Uniform Guidance and the State and Local Fiscal Recovery Funds (SLFRF) Program notes that recipients may use SLFRF payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 codified at 42 USC sections 802 and 803, respectively. Recipients may also use payments subject to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35. Condition: During our testing of the SLFRF Program of the County, we noted two (2) instances where approval control procedures related to the allowable cost compliance requirement were not performed. Context: We addressed these matters with County management who are aware of the allowable cost requirements and the related controls. Effect: Failure to follow internal controls related to allowable costs can lead to noncompliance and spending federal funds on ineligible goods or services or other uses. Cause: Management oversight. Recommendation: We recommend the County review and update its policies and procedures to ensure all internal controls are being followed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program. Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The County is in the process of implementing controls and procedures to ensure all internal control procedures are being performed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program.

Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and/or subrecipients are not suspended, debarred, or otherwise excluded pursuant to the Uniform Guidance. Condition: During our testing of the SLFRF Program of the County, we noted two (2) instances where suspension and debarment was not checked before vendor procurement was completed. Context: We addressed these matters with County management who are aware of the procurement suspension and debarment requirements. Effect: Failure to verify suspension and debarment can lead to noncompliance and procuring with an ineligible vendor. Cause: Management oversight. Recommendation: We recommend the County review and update its policies and procedures to ensure all suspension and debarment procedures are being performed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program. Views of Responsible Officials and Planned Corrective Action: We concur with the finding. The County is in the process of implementing controls and procedures to ensure suspension and debarment procedures are being performed in order to be compliant with requirements under the Uniform Guidance and the SLFRF Program.