2024-007 Program: Santa Ana River Mainstem Project
Federal Financial Assistance Listing Number: 12.U01
Federal Grantor: U.S. Department of Defense
Award No. and Year: 2020
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the Orange County Public Works’ (OCPW) compliance with procurement and
suspension and debarment requirements, we noted for three (3) of three (3) contracts selected
for testing, there was no evidence that the entity was not suspended or debarred or otherwise
excluded from participating in the transaction, prior to entering the contract, in accordance with
County Policy.
In addition, the following information was not provided at the time of the contract award for
three (3) of three (3) contracts selected:
- Byrd Anti-Lobbying Amendment
- Debarment and Suspension
Cause:
The OCPW did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors.
Effect:
The County’s control and compliance were not consistently followed, which required verification
of suspension and debarment prior to entering the contract. Additionally, the OCPW department
did not identify the applicable required provisions of the contract to the contractors at the time
of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) of ten (10) procurement contracts were sampled. The
condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the OCPW department adhere to its procurement procedures requiring the
suspension and debarment verification is performed prior to entering into a covered transaction.
Additionally, we recommend the OCPW modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-010 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Federal Financial Assistance Listing Number: 97.036
Federal Grantor: U.S. Department of Homeland Security
Pass Through: California Office of Emergency Services
Award No. and Year: 059-00000 and 2019
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Condition:
For two (2) out of three (3) project application summary reports tested, the OCPW did not retain
evidence to document the individual who reviewed and approved the required reports.
Cause:
The department’s procedures did not include documenting the review and approval of the reports
prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or
incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of three (3) of nine (9) Grant Project Application Summary Reports were
selecting for testing. The condition above was identified during our procedures over reporting
testing.
Repeat Finding:
No.
Recommendation:
We recommend the OCPW department revise its procedures to include evidence to document
the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-011 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Federal Financial Assistance Listing Number: 97.036
Federal Grantor: U.S. Department of Homeland Security
Pass Through: California Office of Emergency Services
Award No. and Year: 059-00000
Compliance Requirements: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200,
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record
expenditures on the Schedule of Expenditures of Federal Awards (SEFA) when (1) FEMA has
approved the nonfederal entity’s Project, and (2) the nonfederal entity has incurred the eligible
expenditures. FEMA’s approval of a subaward is indicated when FEMA obligates the federal share
of the eligible project cost to the recipient. Federal awards expended in years subsequent to the
fiscal year in which the Project is approved are to be recorded on the nonfederal entity’s SEFA in
those subsequent years.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients
must establish effective internal control over the federal awards, including controls over the
accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the Schedule of Expenditures of Federal Awards and
expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared
Disasters) we noted the County reported expenditures totaling $5,820,436 that should have been
reported on the FY 2023 SEFA, as the granting agency approved the expenditures in FY 2023 and
the County incurred the expenditures prior to June 30, 2023.
Cause:
The County lacks adequate internal controls to ensure the SEFA is completely and accurately
stated.
Effect:
The initial FY 2024 SEFA provided was overstated by $5,820,436. However, we noted these
expenditures would not have had a material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County establish policies and implement internal controls to ensure that
expenditures are reported on the SEFA in accordance with program requirements.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-005 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department
followed their internal control to ensure the vendor was not suspended or debarred prior to
entering the transaction.
Cause:
The Sheriff department did not follow their policy to verify the information described in the
condition prior to entering the transactions.
Effect:
The County’s policy was not consistently followed, which required verification of suspension or
debarment prior to entering the contract. The department subsequently verified that the vendor
was not suspended or debarred.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested.
The condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the Sheriff’s Department adhere to their procurement procedures requiring
the suspension or debarment verification is performed prior to entering into a covered
transaction.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed.
These records must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the Sheriff Department’s compliance with allowable costs/cost principles
requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were
miscalculated.
Cause:
Equitable sharing funds may not be used for salaries, except under certain provisions outlined in
Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department
calculates the allowable portion of personnel salaries using a separate template that contained a
formula error which inaccurately calculated the total salaries costs allocated to the program. The
Sheriff’s department did not have internal controls in place to ensure that the allowed salaries
were being calculated correctly. However, the error was detected after the 5th out of 6 months
in which these types of costs were allocated to the program.
Effect:
Salary costs were allocated to the program in an incorrect amount.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned
costs for the total population was $23,409.
Context/Sampling:
A sample of forty (40) individuals were selected from a population consisting of (840) payroll
transactions.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the Sheriff’s Department establish and maintain internal controls to ensure the
overtime calculations are being accurately allocated to the program.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-005 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department
followed their internal control to ensure the vendor was not suspended or debarred prior to
entering the transaction.
Cause:
The Sheriff department did not follow their policy to verify the information described in the
condition prior to entering the transactions.
Effect:
The County’s policy was not consistently followed, which required verification of suspension or
debarment prior to entering the contract. The department subsequently verified that the vendor
was not suspended or debarred.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested.
The condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the Sheriff’s Department adhere to their procurement procedures requiring
the suspension or debarment verification is performed prior to entering into a covered
transaction.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed.
These records must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the Sheriff Department’s compliance with allowable costs/cost principles
requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were
miscalculated.
Cause:
Equitable sharing funds may not be used for salaries, except under certain provisions outlined in
Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department
calculates the allowable portion of personnel salaries using a separate template that contained a
formula error which inaccurately calculated the total salaries costs allocated to the program. The
Sheriff’s department did not have internal controls in place to ensure that the allowed salaries
were being calculated correctly. However, the error was detected after the 5th out of 6 months
in which these types of costs were allocated to the program.
Effect:
Salary costs were allocated to the program in an incorrect amount.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned
costs for the total population was $23,409.
Context/Sampling:
A sample of forty (40) individuals were selected from a population consisting of (840) payroll
transactions.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the Sheriff’s Department establish and maintain internal controls to ensure the
overtime calculations are being accurately allocated to the program.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-005 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department
followed their internal control to ensure the vendor was not suspended or debarred prior to
entering the transaction.
Cause:
The Sheriff department did not follow their policy to verify the information described in the
condition prior to entering the transactions.
Effect:
The County’s policy was not consistently followed, which required verification of suspension or
debarment prior to entering the contract. The department subsequently verified that the vendor
was not suspended or debarred.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested.
The condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the Sheriff’s Department adhere to their procurement procedures requiring
the suspension or debarment verification is performed prior to entering into a covered
transaction.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed.
These records must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the Sheriff Department’s compliance with allowable costs/cost principles
requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were
miscalculated.
Cause:
Equitable sharing funds may not be used for salaries, except under certain provisions outlined in
Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department
calculates the allowable portion of personnel salaries using a separate template that contained a
formula error which inaccurately calculated the total salaries costs allocated to the program. The
Sheriff’s department did not have internal controls in place to ensure that the allowed salaries
were being calculated correctly. However, the error was detected after the 5th out of 6 months
in which these types of costs were allocated to the program.
Effect:
Salary costs were allocated to the program in an incorrect amount.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned
costs for the total population was $23,409.
Context/Sampling:
A sample of forty (40) individuals were selected from a population consisting of (840) payroll
transactions.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the Sheriff’s Department establish and maintain internal controls to ensure the
overtime calculations are being accurately allocated to the program.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-007 Program: Santa Ana River Mainstem Project
Federal Financial Assistance Listing Number: 12.U01
Federal Grantor: U.S. Department of Defense
Award No. and Year: 2020
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the Orange County Public Works’ (OCPW) compliance with procurement and
suspension and debarment requirements, we noted for three (3) of three (3) contracts selected
for testing, there was no evidence that the entity was not suspended or debarred or otherwise
excluded from participating in the transaction, prior to entering the contract, in accordance with
County Policy.
In addition, the following information was not provided at the time of the contract award for
three (3) of three (3) contracts selected:
- Byrd Anti-Lobbying Amendment
- Debarment and Suspension
Cause:
The OCPW did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors.
Effect:
The County’s control and compliance were not consistently followed, which required verification
of suspension and debarment prior to entering the contract. Additionally, the OCPW department
did not identify the applicable required provisions of the contract to the contractors at the time
of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) of ten (10) procurement contracts were sampled. The
condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the OCPW department adhere to its procurement procedures requiring the
suspension and debarment verification is performed prior to entering into a covered transaction.
Additionally, we recommend the OCPW modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster
Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052,
93.053
Federal Grantor: U.S. Department of Health and Human Services
Passed-Through: California Department of Aging
Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Per 2 CFR 200.332, a pass-through entity must monitor the activities of a subrecipient as necessary
to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and
conditions of the subaward. The pass-through entity is responsible for monitoring the overall
performance of a subrecipient to ensure that the goals and objectives of the subaward are
achieved. In monitoring a subrecipient, a pass-through entity must include the information at 2
CFR 200.332(1) through (4).
Condition:
During our testing of the Orange County Community Resources (OCCR) department’s provisions
for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients
tested, onsite monitoring and follow-up on documented deficiencies was not performed timely.
Cause:
Established policies and procedures related to subrecipient monitoring do not specify the
timeframe within which monitoring must be completed.
Effect:
There is an increased risk that the department’s monitoring procedure may not address the
subrecipient’s risk of noncompliance.
Question Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The
condition above was identified during our procedures over subrecipient monitoring.
Repeat Finding:
No.
Recommendation:
We recommend the department review its established policies and procedures to ensure
subrecipient monitoring is performed timely.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-012 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under
Federal Awards states that in addition to other provisions required by the Federal agency or non-
Federal entity, all contracts made by the non-Federal entity under the Federal award must contain
certain provisions, as applicable.
Condition:
During our testing of the HCA’s compliance with procurement and suspension and debarment
requirements, we noted for two (2) of four (4) samples tested the following information was not
provided at the time of the contract award:
- Clean Air Act and the Federal Water Pollution Control Act
We noted that the tested vendors had been notified of these contract provisions via email.
However, there was no certification or acknowledgement obtained from the vendors to accept
the contract provisions.
Cause:
The HCA did not follow their policy to verify the information described in the condition prior to
entering the transactions and did not consistently ensure that the applicable required provisions
were communicated to contractors at the time the contract was entered into.
Effect:
The HCA department did not identify the applicable required provisions of the contract to the
contractors at the time of the contract award.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of four (4) of eleven (11) procurement contracts were sampled. The
condition above was identified during our procedures over procurement and suspension and
debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department modify and strengthen its current policies and procedures
to ensure that all applicable required provisions are communicated to contracts in accordance
with 2 CFR Appendix II to Part 200.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-013 Program: Epidemiology and Laboratory Capacity for Infectious Disease
Federal Financial Assistance Listing Number: 93.323
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Equipment and Real Property Management
Type of Finding: Material Weakness in Internal Control Over Compliance and Material Instance of
Noncompliance
Criteria:
In accordance with 2 CFR section 200.313(d)(1), property records must be maintained that include
a description of the property, a serial number or other identification number, the source of
funding for the property (including the Federal Award Identification Number), who holds title, the
acquisition date, cost of the property, percentage of Federal participation in the project costs for
the Federal award under which the property was acquired, the location, use and condition of the
property, and any ultimate disposition data including the date of disposal and sale price of the
property.
Condition:
Property records were not maintained in accordance with Uniform Guidance for all property and
equipment purchased. As a result, we were unable to (1) test whether there were any differences
between the physical inventory and equipment records were resolved and (2) sample equipment
from the property records and physically inspect the equipment and determine whether the
equipment is appropriately safeguarded and maintained.
Cause:
The HCA department did not have adequate internal controls to ensure its property records
included all the requirements under Uniform Guidance or properly identify all property and
equipment purchased with federal funds.
Effect:
Property records were not adequately maintained.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. We examined the department’s property records in total.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the HCA department enhance internal controls to ensure its property records
include all the requirements under Uniform Guidance and properly identify all property and
equipment purchased with federal funds.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-014 Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and
Eligibility
Type of Finding: Material Deficiency in Internal Control Over Compliance and Material Instance
of Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.53, General Eligibility
Requirement, states that eligibility for refugee cash assistance is limited to those who:
(1) Are new arrivals who have resided in the U.S. less than the RCA eligibility period
determined by the Office of Refugee Resettlement (ORR) Director in accordance with
Section 400.211;
(2) Are ineligible for TANF, SSI, OAA, AB, APTDD, and AABD programs;
(3) Meet immigration status and identification requirements in Subpart D (Immigration
Status and Identification of Refugees);
(4) Are not full-time students in institutions of higher education, as defined by the ORR.
Per Title 45 Subtitle B Chapter IV Part 400 Subpart E Section 400.66, Eligibility and payment levels
in a publicly-administered RCA program, states that in administering a publicly-administered
refugee cash assistance program, the agency must operate its refugee cash assistance program
consistent with the provisions of its TANF program including the determination of initial and ongoing
eligibility.
Condition:
During our testing of the SSA’s compliance with eligibility and allowable cost/cost principles, we
noted the following:
For two (2) out of forty (40) cases selected for testing, the participants’ country of origin did not
meet the general eligibility requirements of the program.
For two (2) out of forty (40) cases selected for testing, participants received cash assistance
outside of the eligibility period.
For six (6) out of forty (40) cases selected for testing, the SSA did not retain the required
documentation to evidence eligibility under the program.
Cause:
The SSA did not follow their policies to verify and withhold the information described in the
condition and did not consistently ensure that participants were eligible.
Effect:
Benefits were provided to ineligible participants.
Questioned Costs:
Questioned costs for cases tested in which we determined to be ineligible to receive cash
assistance or cases in which there was insufficient documentation to substantiate the eligibility
determination was $7,578.
Context/Sampling:
A nonstatistical sample of forty (40) out of all active program participants were sampled. For
ineligible or unsupported cases we have projected the amount of questioned costs against the
remaining population for a total of $460,581. The condition above was identified during our
procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles
testing.
Repeat Finding:
No.
Recommendation:
We recommend that the SSA department strengthen its internal controls to ensure that program
eligibility criteria are properly supported and retained in case files.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-004 Program: Foster Care Title IV-E
Federal Financial Assistance Listing Number: 93.658
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Social Services
Award No. and Year: 2401CAFOST and 2024, 2301CAFOST and 2023
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities
must comply with the following:
2 CFR 200.332(b) – Evaluate each subrecipient’s risk of noncompliance for purposes of
determining the appropriate subrecipient monitoring related to the subaward. This
evaluation of risk may include consideration of such factors listed in 2 CFR 200.332(b)(1)
through (4).
2 CFR 200.332(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. Pass-through entity monitoring of the subrecipient must
include the information at 2 CFR 200.332(d)(1) through (4).
The California Department of Social Services further clarifies in its County Fiscal Letter No. 23/24-
80 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic
Programs (STRTP) are “considered subrecipients and subject to the same audit requirements and
require the same degree of oversight as other subrecipients”. Further, while there are some
licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs,
“counties are still ultimately responsible for review of these audits and their findings, any followup
to ensure compliance, and any other form of monitoring and oversight required by federal and
state laws and regulations.”
2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other
Persons (and repeated in the California Department of Social Services - County Fiscal Letter No.
21/22 – 115) counties are required to verify that recipients or contracts have not been suspended
or debarred by using the federal SAM (Systems for Award Management)
Condition:
The Social Services Agency (SSA) did not maintain documentation that the subrecipient risk
assessment or the monitoring activity tracker was reviewed.
Cause:
The SSA department did not document its review of the subrecipient risk assessment or the
monitoring activity tracker.
Effect:
The County’s control policies were not consistently followed and documented.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of twelve (12) out of fifty-eight (58) subrecipients were sampled, which
included seven (7) Foster Family Agency, four (4) Short Term Residential Therapeutic Programs,
and one (1) Transitional Housing Placement-Plus Foster Care types. The condition noted above
was identified during our procedures related to subrecipient monitoring and was pervasive to the
program.
Repeat Findings from Prior Years:
Yes, Finding 2023-001.
Recommendation:
We recommend that the County ensure the review over subrecipient monitoring activity is
appropriately documented.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-008 Program: Medicaid Cluster
Federal Financial Assistance Listing Number: 93.778
Federal Grantor: U.S. Department of Health and Human Services
Pass-Through: California Department of Health Care Services
Award No. and Year: Various
Compliance Requirements: Eligibility
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
Title 42 Chapter IV Subchapter C Part 435 Subpart J Section 435.916, Regularly Scheduled
Renewals of Medicaid Eligibility, states that the agency must renew MAGI-based determination
of eligibility once every 12 months and no more frequently than once every 12 months. For non-
MAGI beneficiaries, entities must renew eligibility at least once every 12 months.
Condition:
During our testing of the Social Service Agency’s (SSA) provisions for eligibility requirements, we
noted that for one (1) of sixty (60) samples tested the department did not suspend, or pause,
program eligibility despite being over the income limit for MAGI.
Cause:
The SSA department did not ensure the department’s policies and procedures relating to eligibility
determination were followed. We noted that when a participant is determined to be over the
income limit for MAGI, the participant is placed on a “soft pause” until a determination of
eligibility under non-MAGI or Covered California is made. The department had erroneously
marked the application as complete rather than placing the account on “soft pause” which caused
the case to auto-renew.
Effect:
The County’s control was not consistently followed which caused an inaccurate determination of
eligibility.
Questioned Costs:
None noted.
Context/Sampling:
A non-statistical sample of sixty (60) out of all active program participants were selected for
testing. The condition noted above was identified during our procedures related to eligibility.
Repeat Finding:
No.
Recommendation:
We recommend the SSA department adhere to their policies and procedures to ensure that
participant eligibility determinations and redeterminations are performed accurately.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-015 Program: Medicaid Cluster, Foster Care Title IV-E, Temporary Assistance for Needy Families,
Refugee and Entrant Assistance State/Replacement Designee Administered Programs
Federal Financial Assistance Listing Number: 93.778, 93.658, 93.558, 93.566
Federal Grantor: U.S. Department of Health and Human Services
Award No. and Year: Various
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.413(c)(1), Direct Costs, state that direct costs are those costs that can be
identified specifically with a particular final cost objective, such as a Federal award, or other
internally or externally funded activity, or that can be directly assigned to such activities relatively
easily with a high degree of accuracy. Costs incurred for the same purpose in like circumstances
must be treated consistently as direct or indirect costs.
2 CFR Section 200.416(b), Cost Allocation Plans and Indirect Cost Proposals, states that individual
departments typically charge Federal awards for indirect costs through an indirect cost rate. A
separate indirect cost rate proposal for each operating department is usually necessary to claim
indirect costs under Federal awards. Indirect costs include (1) the indirect costs originating in each
operating department of the State, local government, or Indian Tribe carrying out Federal awards;
and (2) the costs of central governmental services distributed through the central service cost
allocation plan and not otherwise treated as direct costs.
Condition:
During our testing of pooled costs claimed through County Expense Claims, we noted that one (1)
of forty (40) transactions was not a department cost that should have been included in the pooled
cost. This pooled allocation affected the following major programs of SSA: 93.778, 96.658, 93.558,
and 93.566.
Cause:
A journal entry was posted to the SSA Department’s general ledger by another County
Department without SSA’s review/approval for allowable activities. The other County department
inaccurately posted unallowable costs to the SSA department’s general ledger and SSA did not
follow their procedures to ensure allowable costs were properly reported as a cost that can be
specifically assigned to activities of the major programs identified in the County’s expense claims.
Effect:
Unallowable costs were included in the direct cost pool to be further allocated to the federal
funded major programs.
Questioned Costs:
Questioned costs identified amounted to $50,971. The allocation of questioned costs to the major
programs tested were as follows:
Medicaid Cluster (93.558) - $16,329
Foster Care Title IV-E (93.658) - $17,009
Temporary Assistance for Needy Families (93.778) - $17,633
The allocation to the Refugee and Entrant Assistance State/Replacement Designee Programs
(93.566) was of a trivial amount.
Context/Sampling:
A sample of forty (40) amounting to $10,365,065 out of all costs included in the indirect cost pool
of the County expense claims were selected for testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the SSA enhance its procedures to ensure that allocated pooled costs have direct
benefit to the department’s various federally funded programs.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-010 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Federal Financial Assistance Listing Number: 97.036
Federal Grantor: U.S. Department of Homeland Security
Pass Through: California Office of Emergency Services
Award No. and Year: 059-00000 and 2019
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Condition:
For two (2) out of three (3) project application summary reports tested, the OCPW did not retain
evidence to document the individual who reviewed and approved the required reports.
Cause:
The department’s procedures did not include documenting the review and approval of the reports
prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or
incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of three (3) of nine (9) Grant Project Application Summary Reports were
selecting for testing. The condition above was identified during our procedures over reporting
testing.
Repeat Finding:
No.
Recommendation:
We recommend the OCPW department revise its procedures to include evidence to document
the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-011 Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Federal Financial Assistance Listing Number: 97.036
Federal Grantor: U.S. Department of Homeland Security
Pass Through: California Office of Emergency Services
Award No. and Year: 059-00000
Compliance Requirements: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200,
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record
expenditures on the Schedule of Expenditures of Federal Awards (SEFA) when (1) FEMA has
approved the nonfederal entity’s Project, and (2) the nonfederal entity has incurred the eligible
expenditures. FEMA’s approval of a subaward is indicated when FEMA obligates the federal share
of the eligible project cost to the recipient. Federal awards expended in years subsequent to the
fiscal year in which the Project is approved are to be recorded on the nonfederal entity’s SEFA in
those subsequent years.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients
must establish effective internal control over the federal awards, including controls over the
accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the Schedule of Expenditures of Federal Awards and
expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared
Disasters) we noted the County reported expenditures totaling $5,820,436 that should have been
reported on the FY 2023 SEFA, as the granting agency approved the expenditures in FY 2023 and
the County incurred the expenditures prior to June 30, 2023.
Cause:
The County lacks adequate internal controls to ensure the SEFA is completely and accurately
stated.
Effect:
The initial FY 2024 SEFA provided was overstated by $5,820,436. However, we noted these
expenditures would not have had a material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County establish policies and implement internal controls to ensure that
expenditures are reported on the SEFA in accordance with program requirements.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-005 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department
followed their internal control to ensure the vendor was not suspended or debarred prior to
entering the transaction.
Cause:
The Sheriff department did not follow their policy to verify the information described in the
condition prior to entering the transactions.
Effect:
The County’s policy was not consistently followed, which required verification of suspension or
debarment prior to entering the contract. The department subsequently verified that the vendor
was not suspended or debarred.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested.
The condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the Sheriff’s Department adhere to their procurement procedures requiring
the suspension or debarment verification is performed prior to entering into a covered
transaction.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed.
These records must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the Sheriff Department’s compliance with allowable costs/cost principles
requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were
miscalculated.
Cause:
Equitable sharing funds may not be used for salaries, except under certain provisions outlined in
Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department
calculates the allowable portion of personnel salaries using a separate template that contained a
formula error which inaccurately calculated the total salaries costs allocated to the program. The
Sheriff’s department did not have internal controls in place to ensure that the allowed salaries
were being calculated correctly. However, the error was detected after the 5th out of 6 months
in which these types of costs were allocated to the program.
Effect:
Salary costs were allocated to the program in an incorrect amount.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned
costs for the total population was $23,409.
Context/Sampling:
A sample of forty (40) individuals were selected from a population consisting of (840) payroll
transactions.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the Sheriff’s Department establish and maintain internal controls to ensure the
overtime calculations are being accurately allocated to the program.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-005 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department
followed their internal control to ensure the vendor was not suspended or debarred prior to
entering the transaction.
Cause:
The Sheriff department did not follow their policy to verify the information described in the
condition prior to entering the transactions.
Effect:
The County’s policy was not consistently followed, which required verification of suspension or
debarment prior to entering the contract. The department subsequently verified that the vendor
was not suspended or debarred.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested.
The condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the Sheriff’s Department adhere to their procurement procedures requiring
the suspension or debarment verification is performed prior to entering into a covered
transaction.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed.
These records must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the Sheriff Department’s compliance with allowable costs/cost principles
requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were
miscalculated.
Cause:
Equitable sharing funds may not be used for salaries, except under certain provisions outlined in
Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department
calculates the allowable portion of personnel salaries using a separate template that contained a
formula error which inaccurately calculated the total salaries costs allocated to the program. The
Sheriff’s department did not have internal controls in place to ensure that the allowed salaries
were being calculated correctly. However, the error was detected after the 5th out of 6 months
in which these types of costs were allocated to the program.
Effect:
Salary costs were allocated to the program in an incorrect amount.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned
costs for the total population was $23,409.
Context/Sampling:
A sample of forty (40) individuals were selected from a population consisting of (840) payroll
transactions.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the Sheriff’s Department establish and maintain internal controls to ensure the
overtime calculations are being accurately allocated to the program.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-005 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Procurement and Suspension and Debarment
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2
CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part
180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended,
or otherwise excluded from or ineligible for participation in Federal assistance programs or
activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an
entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section
180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded
from participating in the transaction. This verification may be accomplished by (1) checking the
System for Award Management (SAM) Exclusions maintained by the General Services
Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification
from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
Condition:
For three (3) of eight (8) vendors tested, we were not able to verify that the Sheriff Department
followed their internal control to ensure the vendor was not suspended or debarred prior to
entering the transaction.
Cause:
The Sheriff department did not follow their policy to verify the information described in the
condition prior to entering the transactions.
Effect:
The County’s policy was not consistently followed, which required verification of suspension or
debarment prior to entering the contract. The department subsequently verified that the vendor
was not suspended or debarred.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of eight (8) out of thirty-three (33) procurement contracts were tested.
The condition noted above was identified during our procedures related to procurement and
suspension and debarment.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the Sheriff’s Department adhere to their procurement procedures requiring
the suspension or debarment verification is performed prior to entering into a covered
transaction.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
2024-006 Program: Equitable Sharing Program
Federal Financial Assistance Listing Number: 16.922
Federal Grantor: U.S. Department of Justice
Award No. and Year: 2024
Compliance Requirements: Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of
Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must 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.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards
for salaries and wages must be based on records that accurately reflect the work performed.
These records must be supported by a system of internal control that provides reasonable
assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the Sheriff Department’s compliance with allowable costs/cost principles
requirements, we noted that thirty-three (33) of forty (40) overtime cost calculations were
miscalculated.
Cause:
Equitable sharing funds may not be used for salaries, except under certain provisions outlined in
Section V.B.3 of the Equitable Sharing Guide including overtime. The Sheriff’s Department
calculates the allowable portion of personnel salaries using a separate template that contained a
formula error which inaccurately calculated the total salaries costs allocated to the program. The
Sheriff’s department did not have internal controls in place to ensure that the allowed salaries
were being calculated correctly. However, the error was detected after the 5th out of 6 months
in which these types of costs were allocated to the program.
Effect:
Salary costs were allocated to the program in an incorrect amount.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $3,550. However, the total questioned
costs for the total population was $23,409.
Context/Sampling:
A sample of forty (40) individuals were selected from a population consisting of (840) payroll
transactions.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the Sheriff’s Department establish and maintain internal controls to ensure the
overtime calculations are being accurately allocated to the program.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.