Audit 347531

U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing:  1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.

U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing:  1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.

U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing:  1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing:  1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.

U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing:  1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.

U.S. Department of Treasury Federal Financial Assistance Listing 21.027 Coronavirus State and Local Fiscal Recovery Funds Procurement, Suspension & Debarment Significant Deficiency in Internal Control over Compliance Criteria – The Uniform Guidance, Section 200.303 Internal Controls, requires the non-federal entity establish and maintain effective internal controls over federal awards that provide reasonable assurance that awards are being managed in compliance with federal statutes, regulations and the terms and conditions of the federal award. As described in the 2023 compliance supplement, Part 3 includes the requirements of uniform guidance and 2 CFR sections 200.317 through 200.326. We consider factors such as the County’s internal controls and the internal controls over compliance requirements and tests as prescribed in 2 CFR section 200.317 through 200.326. Condition – We selected 4 procurements during our review of overall grant activity for the year ended June 30, 2023. We noted the following in our testing:  1 of the 4 procurements tested was not purchased prior to publishing bids within the local newspaper as required by the County’s Procurement Policy. Cause – Due to insufficient controls over the procurement review process (documentation) the controls are not operating as designed (or not properly implemented to prevent, detect and correct errors timely). Effect – Failure to document the required procurement procedures of the grant may result in noncompliance with the County’s policy. Questioned Costs – None reported. Context/Sampling – A nonstatistical sample of 4 out of 18 expenditures subject to procurement requirements were selected for testing, which accounted for $320,725 of $1,131,449 total expenditures subject to procurement requirements. Repeat Finding from Prior Years – No. Recommendation – We recommend that the County review the procurement approval process to determine why the controls failed and to design and implement controls that will prevent, detect and correct this from occurring in the future. View of Responsible Officials – The County will be more diligent in following their procurement policy. The Finance Department and Grants Team will provide training and guidance to ensure all the other County Departments/Offices are aware of the requirements. Additionally, the upcoming move to a new financial system will lend itself to policy updates and business process updates to ensure this will be less likely to happen.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.

U.S. Department of Labor Iowa Workforce Development Federal Financial Assistance Listing 17.258/17.259/17.278 WIOA Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria – 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Subrecipient monitoring requirements are contained in 2 CFR 200.331 through 2 CFR 200.333 and include requirements to identify the award and applicable requirements to the subrecipient and monitor the activities of the subrecipient. Condition – Iowa Workforce Development did not formally communicate subrecipient monitoring requirements to the County. Consequently, the County did not formally communicate the required information to the subrecipient. No subrecipient agreement was executed. In addition, no monitoring activities were documented. Cause – The County did not have an internal control process in place to ensure subrecipient monitoring requirements were met. Effect – Without the proper communication of applicable requirements and monitoring of the subrecipient, there is a possibility that federal statutes, regulations, and the terms and conditions of the federal award were not complied with. Questioned Costs – None reported. Context/Sampling – $1,437,054 was passed through to one subrecipient during the year ended June 30, 2023. Repeat Finding from Prior Years – Yes. Recommendation – We recommend the County implement a control process which includes the applicable subrecipient monitoring requirements. View of Responsible Officials – This finding is due in part to the fiscal agent agreement with Iowa Workforce Development which does not state that subrecipient monitoring has to be done. Recently, Iowa Workforce Development received a finding from the Department of Labor stating that the fiscal agent agreements improperly place the liability of disallowed costs off on the fiscal agent. This was incorrect, the liability was to stay with the local CEOs. In the wake of the finding, IWD is reissuing the contracts out to the regions to create compliant subrecipient entities within each, and then new fiscal agent agreements will be issued. Additionally, Johnson County will be ending it fiscal agent agreement and no longer continue to be the fiscal agent as of June 30, 2023.