Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.
Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.
Reference Number: 2022-003 Federal Program Title: National Organizations of State and Local Officials Federal Assistance Listing Number: 93.011 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 4 U3SHS42183-01-02; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the National Organizations of State and Local Officials program, we noted that DPH was not able to demonstrate it submitted the required FFAFTA report timely for one (1) of its subrecipients. See Schedule of Findings and Questioned Costs for chart/table. Cause The non-adherence of the FFATA requirement was an oversight by Providing Education, Engagement, Resources and Services (PEERS) project staff. When this issue was identified in 2022, PEERS project staff ensured that contract information was submitted in May 2022. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of one (1) subrecipient award, and we were unable to determine if the FFATA report was submitted timely. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-001 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (2 CFR) ?200.318: (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR ?200.319 states: (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. 2 CFR ?200.320 states: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition During our audit of the Department of Health Services? (DHS) compliance with the procurement requirement for the National Bioterrorism Hospital Preparedness Program, we noted that for one (1) contract, DHS did not provide documentation related to the history of the procurement. Therefore, we were unable to determine whether DHS complied with the procurement requirements related to the method of procurement, competition, and the basis for the contract price. Cause The Director of the DHS, or designee, had delegated authority from the County Board of Supervisors to select, negotiate, and execute agreements with a maximum contract obligation not to exceed $500,000 annually per agreement, per award term. However, DHS was still required to follow the County?s procurement policies. Effect Failure to document the history of procurements results in noncompliance with the procurement requirements with 2 CFR 200.317, 200.318, 200.319 and 200.320. Questioned Costs Questioned costs were not identified. Context For the four (4) contracts selected for testing, which totaled $478,418 from a population of eleven (11) contracts with expenditures totaling $594,798, DHS did not provide documentation of the history of procurement for one (1) contract. The sample was not a statistically valid sample. Recommendation We recommend that DHS maintain records sufficient to detail the history of procurement and to ensure compliance with procurement requirements.
Reference Number: 2022-002 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Health Services? (DHS) compliance with the reporting requirement for the National Bioterrorism Hospital Preparedness Program, we noted that DHS was not able to demonstrate it submitted the required FFAFTA reports timely for seventeen (17) of its subawards. Furthermore, DHS did not submit a FFAFTA report for one (1) of its subaward. See Schedule of Findings and Questioned Costs for chart/table. Cause DHS was unable to access the submittal history for the reports because the previous employee responsible for FFATA reporting was no longer a DHS employee. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Eighteen (18) subawards requiring the submission of a FFATA report were selected from a total population of seventy eight (78) subawards. For seventeen (17) subawards, we were unable to determine whether the reports were submitted timely; and one (1) subaward was not reported. The sample was not a statistically valid sample. Recommendation We recommend that the DHS strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).
Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.
Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).
Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.
Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-007 Federal Program Title: Guardianship Assistance Federal Assistance Listing: 93.090 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No.16/17-69, 14/15-40, 11/12-18; Fiscal Year 2021-22 Name of Department: Department of Children and Family Services Category of Finding: Eligibility Criteria The compliance criteria pertaining to the Guardianship Assistance program are as follows: 1. The kinship guardianship assistance agreement must be a written and binding document entered into through negotiations with the prospective relative guardian and contain information concerning; the amount of, and manner in which, each kinship guardianship assistance payment will be provided under the agreement, and the manner in which the payment may be adjusted periodically, in consultation with the relative guardian, based on the circumstances of the relative guardian and the needs of the child (42 USC 673(d)(1)(A)(i) and 673(d)(1)(B)(i)).) 2. The Title IV-E agency may amend its Title IV-E plan to provide for a definition of a ?child? as an individual who has not attained 19, 20, or 21 years old (as the Title IV-E agency may elect) (42 USC 675(8)(B)(iii)). This definition of a child will then permit payment of kinship guardianship assistance for a child who is over age 18 (where the Title IV-E agency does not determine that the child has a mental or physical disability which warrants the continuation of assistance up to age 21) only if such a youth is part of a kinship guardianship assistance agreement that is in effect under Section 473 of the Social Security Act and the youth had attained 16 years of age before the agreement became effective. As an additional requirement, a youth over age 18 must also (as elected by the Title IV-E agency) be (a) completing secondary school (or equivalent); (b) enrolled in post-secondary or vocational school; (c) participating in a program or activity that promotes or removes barriers to employment; (d) employed 80 hours a month; or (e) incapable of any of these due to a documented medical condition (42 USC 675(8)(B)). Condition Of the sixty (60) samples selected for testing, we noted that for two (2) samples the form (KG 3) Kin-GAP Mutual Agreement for Nonminor Former Dependents was not provided. Therefore, we were not able to verify that the agreement for the participant was signed and was in effect when benefits were paid. This is a repeat finding of 2021-003. Cause The required form for participants, the Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG 3), could not be located. DCFS management represented that they were most likely misplaced. Effect The lack of documentation to support eligibility determinations results in questioned costs and noncompliance with 42 USC 673 and 42 USC 675. Questioned Costs $1,059 (known questioned costs based on FY 2021-22 assistance payments for the 2 samples) Context From a population of $33,700,076 of FY 2021-22 assistance payments, two (2) samples with total payments of $1,059 were noted. The sample was not a statistically valid sample. Recommendation We recommend that DCFS maintain required form Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG 3) in the Guardianship Assistance case files.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.
Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.
Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.
Reference Number: 2022-003 Federal Program Title: National Organizations of State and Local Officials Federal Assistance Listing Number: 93.011 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 4 U3SHS42183-01-02; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the National Organizations of State and Local Officials program, we noted that DPH was not able to demonstrate it submitted the required FFAFTA report timely for one (1) of its subrecipients. See Schedule of Findings and Questioned Costs for chart/table. Cause The non-adherence of the FFATA requirement was an oversight by Providing Education, Engagement, Resources and Services (PEERS) project staff. When this issue was identified in 2022, PEERS project staff ensured that contract information was submitted in May 2022. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of one (1) subrecipient award, and we were unable to determine if the FFATA report was submitted timely. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.
Reference Number: 2022-001 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (2 CFR) ?200.318: (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR ?200.319 states: (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. 2 CFR ?200.320 states: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition During our audit of the Department of Health Services? (DHS) compliance with the procurement requirement for the National Bioterrorism Hospital Preparedness Program, we noted that for one (1) contract, DHS did not provide documentation related to the history of the procurement. Therefore, we were unable to determine whether DHS complied with the procurement requirements related to the method of procurement, competition, and the basis for the contract price. Cause The Director of the DHS, or designee, had delegated authority from the County Board of Supervisors to select, negotiate, and execute agreements with a maximum contract obligation not to exceed $500,000 annually per agreement, per award term. However, DHS was still required to follow the County?s procurement policies. Effect Failure to document the history of procurements results in noncompliance with the procurement requirements with 2 CFR 200.317, 200.318, 200.319 and 200.320. Questioned Costs Questioned costs were not identified. Context For the four (4) contracts selected for testing, which totaled $478,418 from a population of eleven (11) contracts with expenditures totaling $594,798, DHS did not provide documentation of the history of procurement for one (1) contract. The sample was not a statistically valid sample. Recommendation We recommend that DHS maintain records sufficient to detail the history of procurement and to ensure compliance with procurement requirements.
Reference Number: 2022-002 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Health Services? (DHS) compliance with the reporting requirement for the National Bioterrorism Hospital Preparedness Program, we noted that DHS was not able to demonstrate it submitted the required FFAFTA reports timely for seventeen (17) of its subawards. Furthermore, DHS did not submit a FFAFTA report for one (1) of its subaward. See Schedule of Findings and Questioned Costs for chart/table. Cause DHS was unable to access the submittal history for the reports because the previous employee responsible for FFATA reporting was no longer a DHS employee. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Eighteen (18) subawards requiring the submission of a FFATA report were selected from a total population of seventy eight (78) subawards. For seventeen (17) subawards, we were unable to determine whether the reports were submitted timely; and one (1) subaward was not reported. The sample was not a statistically valid sample. Recommendation We recommend that the DHS strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).
Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.
Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).
Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.
Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that 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 During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.
Reference Number: 2022-007 Federal Program Title: Guardianship Assistance Federal Assistance Listing: 93.090 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No.16/17-69, 14/15-40, 11/12-18; Fiscal Year 2021-22 Name of Department: Department of Children and Family Services Category of Finding: Eligibility Criteria The compliance criteria pertaining to the Guardianship Assistance program are as follows: 1. The kinship guardianship assistance agreement must be a written and binding document entered into through negotiations with the prospective relative guardian and contain information concerning; the amount of, and manner in which, each kinship guardianship assistance payment will be provided under the agreement, and the manner in which the payment may be adjusted periodically, in consultation with the relative guardian, based on the circumstances of the relative guardian and the needs of the child (42 USC 673(d)(1)(A)(i) and 673(d)(1)(B)(i)).) 2. The Title IV-E agency may amend its Title IV-E plan to provide for a definition of a ?child? as an individual who has not attained 19, 20, or 21 years old (as the Title IV-E agency may elect) (42 USC 675(8)(B)(iii)). This definition of a child will then permit payment of kinship guardianship assistance for a child who is over age 18 (where the Title IV-E agency does not determine that the child has a mental or physical disability which warrants the continuation of assistance up to age 21) only if such a youth is part of a kinship guardianship assistance agreement that is in effect under Section 473 of the Social Security Act and the youth had attained 16 years of age before the agreement became effective. As an additional requirement, a youth over age 18 must also (as elected by the Title IV-E agency) be (a) completing secondary school (or equivalent); (b) enrolled in post-secondary or vocational school; (c) participating in a program or activity that promotes or removes barriers to employment; (d) employed 80 hours a month; or (e) incapable of any of these due to a documented medical condition (42 USC 675(8)(B)). Condition Of the sixty (60) samples selected for testing, we noted that for two (2) samples the form (KG 3) Kin-GAP Mutual Agreement for Nonminor Former Dependents was not provided. Therefore, we were not able to verify that the agreement for the participant was signed and was in effect when benefits were paid. This is a repeat finding of 2021-003. Cause The required form for participants, the Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG 3), could not be located. DCFS management represented that they were most likely misplaced. Effect The lack of documentation to support eligibility determinations results in questioned costs and noncompliance with 42 USC 673 and 42 USC 675. Questioned Costs $1,059 (known questioned costs based on FY 2021-22 assistance payments for the 2 samples) Context From a population of $33,700,076 of FY 2021-22 assistance payments, two (2) samples with total payments of $1,059 were noted. The sample was not a statistically valid sample. Recommendation We recommend that DCFS maintain required form Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG 3) in the Guardianship Assistance case files.
Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.