Audit 351867

FY End
2024-06-30
Total Expended
$120.73M
Findings
18
Programs
80
Organization: Clackamas County, Oregon (OR)
Year: 2024 Accepted: 2025-03-31
Auditor: Moss Adams LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
547928 2024-001 Significant Deficiency - L
547929 2024-001 Significant Deficiency - L
547930 2024-001 Significant Deficiency - L
547931 2024-001 Significant Deficiency - L
547932 2024-001 Significant Deficiency - L
547933 2024-002 Significant Deficiency - I
547934 2024-002 Significant Deficiency - I
547935 2024-003 Significant Deficiency - B
547936 2024-003 Significant Deficiency - B
1124370 2024-001 Significant Deficiency - L
1124371 2024-001 Significant Deficiency - L
1124372 2024-001 Significant Deficiency - L
1124373 2024-001 Significant Deficiency - L
1124374 2024-001 Significant Deficiency - L
1124375 2024-002 Significant Deficiency - I
1124376 2024-002 Significant Deficiency - I
1124377 2024-003 Significant Deficiency - B
1124378 2024-003 Significant Deficiency - B

Programs

ALN Program Spent Major Findings
14.239 Home Investment Partnerships Program $19.25M Yes 0
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $12.53M - 0
93.568 Low-Income Home Energy Assistance $3.48M - 0
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.44M - 0
93.563 Child Support Services $1.38M - 0
14.267 Continuum of Care Program $1.37M - 0
14.218 Community Development Block Grants/entitlement Grants $1.13M Yes 1
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $883,664 - 0
16.922 Equitable Sharing Program $741,372 - 0
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $572,458 - 0
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $553,557 - 0
14.256 Neighborhood Stabilization Program (recovery Act Funded) $428,223 - 0
16.575 Crime Victim Assistance $378,180 - 0
93.052 National Family Caregiver Support, Title Iii, Part E $372,173 - 0
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $368,505 - 0
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $351,376 - 0
93.069 Public Health Emergency Preparedness $304,174 - 0
81.042 Weatherization Assistance for Low-Income Persons $260,966 - 0
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $250,000 - 0
93.958 Block Grants for Community Mental Health Services $243,180 - 0
93.569 Community Services Block Grant $241,667 - 0
97.012 Boating Safety Financial Assistance $224,871 - 0
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $222,781 - 0
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $211,253 - 0
20.509 Formula Grants for Rural Areas and Tribal Transit Program $209,474 - 0
17.805 Homeless Veterans’ Reintegration Program $200,112 - 0
93.053 Nutrition Services Incentive Program $187,146 - 0
21.016 Equitable Sharing $175,324 - 0
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $171,699 - 0
93.268 Immunization Cooperative Agreements $171,595 - 0
16.812 Second Chance Act Reentry Initiative $170,880 - 0
93.499 Low Income Household Water Assistance Program $161,946 - 0
93.558 Temporary Assistance for Needy Families $158,084 - 0
97.042 Emergency Management Performance Grants $140,287 - 0
93.136 Injury Prevention and Control Research and State and Community Based Programs $125,833 - 0
93.526 Grants for Capital Development in Health Centers $123,786 - 0
93.994 Maternal and Child Health Services Block Grant to the States $122,446 - 0
94.016 Americorps Seniors Senior Companion Program (scp) 94.016 $120,861 - 0
21.023 Emergency Rental Assistance Program $89,092 - 0
93.940 Hiv Prevention Activities Health Department Based $87,470 - 0
93.556 Marylee Allen Promoting Safe and Stable Families Program $76,247 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $71,687 - 0
20.526 Buses and Bus Facilities Formula, Competitive, and Low Or No Emissions Programs $68,000 - 0
16.585 Treatment Court Discretionary Grant Program $67,421 - 0
16.738 Edward Byrne Memorial Justice Assistance Grant Program $62,435 - 0
14.231 Emergency Solutions Grant Program $61,946 - 0
66.468 Drinking Water State Revolving Fund $60,416 - 0
66.432 State Public Water System Supervision $60,416 - 0
20.513 Enhanced Mobility of Seniors and Individuals with Disabilities $60,075 - 0
20.205 Highway Planning and Construction $54,112 - 0
93.217 Family Planning Services $51,391 - 0
10.447 Rural Multi-Family Housing Revitalization Demonstration Program (mpr) $50,000 - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $46,637 - 0
17.259 Wioa Youth Activities $43,000 - 0
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $41,200 - 0
21.032 Local Assistance and Tribal Consistency Fund $40,000 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $34,768 Yes 2
94.017 Americorps Seniors Senior Demonstration Program (fgp) 94.017 $32,247 - 0
93.778 Medical Assistance Program $25,168 - 0
93.527 Grants for New and Expanded Services Under the Health Center Program $22,521 - 0
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $22,431 - 0
93.324 State Health Insurance Assistance Program $19,500 - 0
81.U01 Low-Income Energy Efficiency Program (liee) $19,185 - 0
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $18,500 - 0
20.600 State and Community Highway Safety $14,116 - 0
97.067 Homeland Security Grant Program $13,188 - 0
15.234 Secure Rural Schools and Community Self-Determination $13,027 - 0
93.071 Medicare Enrollment Assistance Program $8,475 - 0
20.507 Federal Transit Formula Grants $6,984 - 0
10.664 Cooperative Forestry Assistance $6,947 - 0
93.658 Foster Care Title IV-E $5,333 - 0
20.616 National Priority Safety Programs $5,259 - 0
90.400 Help America Vote College Program $3,141 - 0
16.710 Public Safety Partnership and Community Policing Grants $2,455 - 0
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $1,588 - 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $1,518 - 0
20.218 Motor Carrier Safety Assistance $1,424 - 0
15.622 Sportfishing and Boating Safety Act $1,119 - 0
20.939 Safe Streets and Roads for All $521 - 0
97.039 Hazard Mitigation Grant $-4,888 - 0

Contacts

Name Title Type
NVWKAVB8JND6 Bouavieng Bounnam Auditee
5037425422 Kevin Mullerleile Auditor
No contacts on file

Notes to SEFA

Title: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The Schedule of Expenditures of Federal Awards (the Schedule) is presented using the modified accrual basis of accounting, which is described in Note 1 to the basic financial statements of Clackamas County, Oregon (the County). Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) wherein certain types of expenses are not allowable or are limited as to reimbursement. The Pass through entity identifying numbers are presented where applicable. De Minimis Rate Used: N Rate Explanation: During the fiscal year ended, June 30, 2024, the County did not elect to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Schedule of Expenditures of Federal Awards (the Schedule) is presented using the modified accrual basis of accounting, which is described in Note 1 to the basic financial statements of Clackamas County, Oregon (the County). Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) wherein certain types of expenses are not allowable or are limited as to reimbursement. The passthrough entity identifying numbers are presented where applicable.
Title: ELECTION OF DE MINIMIS INDIRECT COST RATE Accounting Policies: The Schedule of Expenditures of Federal Awards (the Schedule) is presented using the modified accrual basis of accounting, which is described in Note 1 to the basic financial statements of Clackamas County, Oregon (the County). Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) wherein certain types of expenses are not allowable or are limited as to reimbursement. The Pass through entity identifying numbers are presented where applicable. De Minimis Rate Used: N Rate Explanation: During the fiscal year ended, June 30, 2024, the County did not elect to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. During the fiscal year ended June 30, 2024, the County did not elect to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance.
Title: BASIS OF PRESENTATION Accounting Policies: The Schedule of Expenditures of Federal Awards (the Schedule) is presented using the modified accrual basis of accounting, which is described in Note 1 to the basic financial statements of Clackamas County, Oregon (the County). Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) wherein certain types of expenses are not allowable or are limited as to reimbursement. The Pass through entity identifying numbers are presented where applicable. De Minimis Rate Used: N Rate Explanation: During the fiscal year ended, June 30, 2024, the County did not elect to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The Schedule presents the activity of all federally-funded programs of the County, except for the Housing Authority of Clackamas County (HACC) which issues a separate report. The reporting entity is defined in Note 1 to the County’s basic financial statements. The information in the Schedule is presented in accordance with the requirements of the Uniform Guidance. Because the Schedule presents only a selected portion of the operations of the County, it is not intended to and does not present the financial position, changes in financial position, or the cash flows of the County.
Title: REVOLVING LOAN PROGRAMS Accounting Policies: The Schedule of Expenditures of Federal Awards (the Schedule) is presented using the modified accrual basis of accounting, which is described in Note 1 to the basic financial statements of Clackamas County, Oregon (the County). Such expenditures are recognized following the cost principles contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) wherein certain types of expenses are not allowable or are limited as to reimbursement. The Pass through entity identifying numbers are presented where applicable. De Minimis Rate Used: N Rate Explanation: During the fiscal year ended, June 30, 2024, the County did not elect to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. The County makes loans to developers for the construction of low-income housing units. The seed money for these loans used to establish the program initially was provided through Federal funds under the Rural Development Multi-Family Housing Revitalization Demonstration Program (ALN #10.447), Community Development Block Grants/Entitlement Grants (ALN #14.218), HOME Investment Partnerships Program (ALN #14.239), and Neighborhood Stabilization Program (ALN #14.256). The County’s responsibility over these loans is to ensure that a specified percentage of the total rental units are rented to low-income individuals, and the ongoing compliance requirements relate to the accumulated loan balances. The outstanding loan balances as of June 30, 2024 consists of: See the Notes to the SEFA for chart/table.

Finding Details

FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-002 – Procurement, Suspension and Debarment – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods and services exceeding $25,000. Condition: For two of the contracts tested, there was no evidence of verification from sam.gov being obtained to verify vendors were not suspended or debarred prior to conducting business. There was also no evidence in the County’s contract with the vendor that the appropriate language had been included. Context: Of the 39 vendors that had expenditures greater than $25,000, we selected four vendors for procurement testing. Effect: The County could be transacting with parties that are suspended or debarred and may be subject to questioned costs or other sanctions from funding agencies. However, during the course of the audit we verified these vendors were not previously suspended or debarred. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Repeat finding: No Recommendation: We recommend that before the County executes contracts with vendors that exceed $25,000, the vendor is compared to the listing of suspended and debarred vendors on the sam.gov website and that this verification is properly documented. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-002 – Procurement, Suspension and Debarment – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods and services exceeding $25,000. Condition: For two of the contracts tested, there was no evidence of verification from sam.gov being obtained to verify vendors were not suspended or debarred prior to conducting business. There was also no evidence in the County’s contract with the vendor that the appropriate language had been included. Context: Of the 39 vendors that had expenditures greater than $25,000, we selected four vendors for procurement testing. Effect: The County could be transacting with parties that are suspended or debarred and may be subject to questioned costs or other sanctions from funding agencies. However, during the course of the audit we verified these vendors were not previously suspended or debarred. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Repeat finding: No Recommendation: We recommend that before the County executes contracts with vendors that exceed $25,000, the vendor is compared to the listing of suspended and debarred vendors on the sam.gov website and that this verification is properly documented. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-003 – Allowable Costs – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Recipients may use State and Local Fiscal Recovery Funds (SLFRF) for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, codified at 42 USC sections 802 and 803, and as amended by the 2023 Consolidated Appropriations Act. In general, recipients may use payments from SLFRF to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers, invest in water, sewer, and broadband infrastructure, provide emergency relief from natural disasters or the negative economic impacts of natural disasters, fund projects eligible under certain programs administered by the U.S. Department of Transportation, and fund projects eligible under the programs established in Title I of the Housing and Community Development Act of 1974. Condition: For nine of the items tested, we noted the County had charged contracted services for temporary employees to assist with either accounting or Ballot Measure 108, neither of which are considered allowable in accordance with the regulations. Context: Of the 35 disbursements that were tested, 9 items were identified that included detail that did not support that the expenditure was allowable in accordance with the regulations. Effect: The County charged expenditures that were unallowable. Cause: Journal entries were posted to charge the expenditures to the grant without proper review of the supporting documentation, including timesheets, to verify whether the expenditure would be considered allowable in accordance with the regulations. Repeat finding: No Recommendation: We recommend that the County thoroughly review all supporting documentation prior to charging expenditures to a Federal grant to ensure the amount is allowable in accordance with the respective regulations. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-003 – Allowable Costs – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Recipients may use State and Local Fiscal Recovery Funds (SLFRF) for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, codified at 42 USC sections 802 and 803, and as amended by the 2023 Consolidated Appropriations Act. In general, recipients may use payments from SLFRF to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers, invest in water, sewer, and broadband infrastructure, provide emergency relief from natural disasters or the negative economic impacts of natural disasters, fund projects eligible under certain programs administered by the U.S. Department of Transportation, and fund projects eligible under the programs established in Title I of the Housing and Community Development Act of 1974. Condition: For nine of the items tested, we noted the County had charged contracted services for temporary employees to assist with either accounting or Ballot Measure 108, neither of which are considered allowable in accordance with the regulations. Context: Of the 35 disbursements that were tested, 9 items were identified that included detail that did not support that the expenditure was allowable in accordance with the regulations. Effect: The County charged expenditures that were unallowable. Cause: Journal entries were posted to charge the expenditures to the grant without proper review of the supporting documentation, including timesheets, to verify whether the expenditure would be considered allowable in accordance with the regulations. Repeat finding: No Recommendation: We recommend that the County thoroughly review all supporting documentation prior to charging expenditures to a Federal grant to ensure the amount is allowable in accordance with the respective regulations. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-001 – Reporting – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Prime grant recipients awarded a federal contract greater than or equal to $30,000 are subject to Federal Funding Accountability and Transparency Act (FFATA) subaward reporting requirements. The prime awardee is required to file a FFATA subaward report by the end of the month following the month in which the prime contractor awards any subcontract greater than or equal to $30,000. In addition, as a condition of the award, the County is required to submit cash-on-hand reports quarterly. Condition: During our testing, the County did not file a FFATA report for one of its subrecipients that was granted the sub-award during the fiscal year. In addition, we were provided with documentation that indicated the County did not file two of its quarterly cash-on-hand reports by the due date specified in the award document. Context: Of the six subrecipients that received funding, only one subrecipient was awarded funds in the current fiscal year, and no FFATA report was filed. Of the four cash-on-hand reports, two of four reports was not filed by the due date. Effect: The FFATA report was not filed within 30 days of the sub-award. The failure to have the FFATA reports submitted could result in the submission of inaccurate or incomplete information to federal agencies, potentially leading to non-compliance with federal requirements, mismanagement of funds, and jeopardizing future funding. In addition, two cash-on-hand reports were not filed by the due date specified in the award document. Cause: The County does not have an effective control in place to monitor reporting timelines and submission. Repeat finding: No. Recommendation: We recommend the County work to establish an internal tracking system to memorialize reporting deadlines and track the submission of required reports under the program. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-002 – Procurement, Suspension and Debarment – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods and services exceeding $25,000. Condition: For two of the contracts tested, there was no evidence of verification from sam.gov being obtained to verify vendors were not suspended or debarred prior to conducting business. There was also no evidence in the County’s contract with the vendor that the appropriate language had been included. Context: Of the 39 vendors that had expenditures greater than $25,000, we selected four vendors for procurement testing. Effect: The County could be transacting with parties that are suspended or debarred and may be subject to questioned costs or other sanctions from funding agencies. However, during the course of the audit we verified these vendors were not previously suspended or debarred. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Repeat finding: No Recommendation: We recommend that before the County executes contracts with vendors that exceed $25,000, the vendor is compared to the listing of suspended and debarred vendors on the sam.gov website and that this verification is properly documented. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-002 – Procurement, Suspension and Debarment – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods and services exceeding $25,000. Condition: For two of the contracts tested, there was no evidence of verification from sam.gov being obtained to verify vendors were not suspended or debarred prior to conducting business. There was also no evidence in the County’s contract with the vendor that the appropriate language had been included. Context: Of the 39 vendors that had expenditures greater than $25,000, we selected four vendors for procurement testing. Effect: The County could be transacting with parties that are suspended or debarred and may be subject to questioned costs or other sanctions from funding agencies. However, during the course of the audit we verified these vendors were not previously suspended or debarred. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Repeat finding: No Recommendation: We recommend that before the County executes contracts with vendors that exceed $25,000, the vendor is compared to the listing of suspended and debarred vendors on the sam.gov website and that this verification is properly documented. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-003 – Allowable Costs – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Recipients may use State and Local Fiscal Recovery Funds (SLFRF) for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, codified at 42 USC sections 802 and 803, and as amended by the 2023 Consolidated Appropriations Act. In general, recipients may use payments from SLFRF to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers, invest in water, sewer, and broadband infrastructure, provide emergency relief from natural disasters or the negative economic impacts of natural disasters, fund projects eligible under certain programs administered by the U.S. Department of Transportation, and fund projects eligible under the programs established in Title I of the Housing and Community Development Act of 1974. Condition: For nine of the items tested, we noted the County had charged contracted services for temporary employees to assist with either accounting or Ballot Measure 108, neither of which are considered allowable in accordance with the regulations. Context: Of the 35 disbursements that were tested, 9 items were identified that included detail that did not support that the expenditure was allowable in accordance with the regulations. Effect: The County charged expenditures that were unallowable. Cause: Journal entries were posted to charge the expenditures to the grant without proper review of the supporting documentation, including timesheets, to verify whether the expenditure would be considered allowable in accordance with the regulations. Repeat finding: No Recommendation: We recommend that the County thoroughly review all supporting documentation prior to charging expenditures to a Federal grant to ensure the amount is allowable in accordance with the respective regulations. Views of responsible officials: Management agrees with the auditor recommendation.
FINDING 2024-003 – Allowable Costs – Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance See the Notes to the SEFA for chart/table. Criteria or specific requirement: Recipients may use State and Local Fiscal Recovery Funds (SLFRF) for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, codified at 42 USC sections 802 and 803, and as amended by the 2023 Consolidated Appropriations Act. In general, recipients may use payments from SLFRF to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers, invest in water, sewer, and broadband infrastructure, provide emergency relief from natural disasters or the negative economic impacts of natural disasters, fund projects eligible under certain programs administered by the U.S. Department of Transportation, and fund projects eligible under the programs established in Title I of the Housing and Community Development Act of 1974. Condition: For nine of the items tested, we noted the County had charged contracted services for temporary employees to assist with either accounting or Ballot Measure 108, neither of which are considered allowable in accordance with the regulations. Context: Of the 35 disbursements that were tested, 9 items were identified that included detail that did not support that the expenditure was allowable in accordance with the regulations. Effect: The County charged expenditures that were unallowable. Cause: Journal entries were posted to charge the expenditures to the grant without proper review of the supporting documentation, including timesheets, to verify whether the expenditure would be considered allowable in accordance with the regulations. Repeat finding: No Recommendation: We recommend that the County thoroughly review all supporting documentation prior to charging expenditures to a Federal grant to ensure the amount is allowable in accordance with the respective regulations. Views of responsible officials: Management agrees with the auditor recommendation.