Audit 352056

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,506,689 $3,506,689 $3,506,689 $3,506,689 $3,506,689 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-003. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,506,689 $3,506,689 $3,506,689 $3,506,689 $3,506,689 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-003. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our special tests and provisions testing, we noted three (3) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the Rights, Responsibilities, and Important Information (form SAWS 2A SAR) for support the applicants initial interview application. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. The County’s policies and procedures did not ensure that all SAWS 2A SAR forms were retained with signatures in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In three (3) out of 60 cases, we found that the County did not retain a copy of the CW2.1 to evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In one (1) out of 60 cases, we found that the County did not retain a copy of the SAWS 2A SAR to evidence the applicants’ rights and responsibilities. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-004. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Health Care Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 28 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. We also identified 3 instances out of 60 sampled in which the redetermination for participants was not completed, but they were still determined as eligible within the system and therefore continued to receive benefits. Cause: The County’s policies and procedures did not ensure that timely redeterminations are performed for all program recipients. Additionally, the County had been in the process of migrating to CalSAW and there were system issues causing cases to not be discontinued after they should have been determined as ineligible. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 6,215. A sample of 60 Medicaid recipients were selected out of 161,732. Repeat Finding from Prior Year(s): Yes. See prior year finding 2023-008. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified the following: 1. Five (5) instances out of 60 cases were missing all eligibility documentation. This included the documentation of the determination of eligibility and redetermination in the period under audit. The missing documentation included the records to evidence compliance with the eligibility criteria. 2. Two (2) instances out of 60 cases were missing the Self Declaration Statement form when the applicant was unable to provide acceptable documentation for proof of income, proof of address, or proof of identification. Cause: The County relies on the State of California Department of Public Health eligibility and documentation system, Women, Infant, and Children Web Information System Exchange (WIC WISE) to retain the case records. Management stated that WIC WISE automatically deletes the documentation for children 6 months after the child reaches 5 years old, and therefore was not available for the selected cases. The County’s policies and procedures did not ensure that the Self Declaration Statements were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 60 program participants out of a population of 9,060 were selected for testing. The five (5) and two (2) instances identified in the condition section above were part of the same population of 60 participants. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to retain documentation to evidence its compliance with program eligibility requirements for those documents which will not be retained in WIC WISE. We also recommend that the county strengthen its current policies and procedures with regards to obtaining the required forms at the initial application and periodic redeterminations. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: As a result of our procurement testing, we identified one (1) instance out of a population of one (1) where the County did not document the history of the procurement, including the rationale for method of procurement, selection of contract type, basis for contractor selection, and basis for the contract price. Cause: The County’s procurement policy and procedures do not comply with the uniform guidance requirements to obtain document the history of each procurement transaction. Effect: The County did not comply with the procurement, suspension and debarment requirements. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over procurement. We selected 100% of the procurements in the year under audit. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that the history of each procurement transaction. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Foster Care Federal Financial Assistance Listing No.: 93.658 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted two (2) out of 44 cases were incorrectly identified as federal eligible by the County. Cause: The County transitioned to the California Statewide Automated Welfare System (CalSAWS) in the fiscal year 2024. During this transition, the case was inadvertently converted to a federal case in error. Effect: The County did not comply with the eligibility requirements. Questioned Costs: Known questioned costs were $15,517. Projected questioned costs were $92,568. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 44 cases out of a population 221 were selected for testing. The sample represented $579,924 in benefits out of $2,036,487. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards reviewing cases for federal eligibility. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Foster Care Federal Financial Assistance Listing No.: 93.658 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. This includes internal controls to ensure that federal funds are used only for federally eligible cases. Condition: As a result of our allowable activities and allowed cost testing, we noted one (1) out of 60 benefit payments which was paid to an eligible participant for federal benefits. Cause: The County transitioned to the California Statewide Automated Welfare System (CalSAWS) in the fiscal year 2024. During this transition, the case was inadvertently converted to a federal case in error. Effect: The County did not comply with the allowed activities and allowable costs requirements. Questioned Costs: Known questioned costs were $1,319. Projected questioned costs were $25,151. Context/Sampling: The condition noted above was found during our testing procedures over allowable activities and allowed costs. A sample of 60 benefit payments out of a population 2,293 were selected for testing. Our sample represented benefit payments of $53,252 out of $2,036,487. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards reviewing cases for federal eligibility prior to authorizing payment of benefits. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,506,689 $3,506,689 $3,506,689 $3,506,689 $3,506,689 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-003. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,506,689 $3,506,689 $3,506,689 $3,506,689 $3,506,689 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-003. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our special tests and provisions testing, we noted three (3) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the Rights, Responsibilities, and Important Information (form SAWS 2A SAR) for support the applicants initial interview application. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. The County’s policies and procedures did not ensure that all SAWS 2A SAR forms were retained with signatures in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In three (3) out of 60 cases, we found that the County did not retain a copy of the CW2.1 to evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In one (1) out of 60 cases, we found that the County did not retain a copy of the SAWS 2A SAR to evidence the applicants’ rights and responsibilities. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-004. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Health Care Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 28 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. We also identified 3 instances out of 60 sampled in which the redetermination for participants was not completed, but they were still determined as eligible within the system and therefore continued to receive benefits. Cause: The County’s policies and procedures did not ensure that timely redeterminations are performed for all program recipients. Additionally, the County had been in the process of migrating to CalSAW and there were system issues causing cases to not be discontinued after they should have been determined as ineligible. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 6,215. A sample of 60 Medicaid recipients were selected out of 161,732. Repeat Finding from Prior Year(s): Yes. See prior year finding 2023-008. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified the following: 1. Five (5) instances out of 60 cases were missing all eligibility documentation. This included the documentation of the determination of eligibility and redetermination in the period under audit. The missing documentation included the records to evidence compliance with the eligibility criteria. 2. Two (2) instances out of 60 cases were missing the Self Declaration Statement form when the applicant was unable to provide acceptable documentation for proof of income, proof of address, or proof of identification. Cause: The County relies on the State of California Department of Public Health eligibility and documentation system, Women, Infant, and Children Web Information System Exchange (WIC WISE) to retain the case records. Management stated that WIC WISE automatically deletes the documentation for children 6 months after the child reaches 5 years old, and therefore was not available for the selected cases. The County’s policies and procedures did not ensure that the Self Declaration Statements were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 60 program participants out of a population of 9,060 were selected for testing. The five (5) and two (2) instances identified in the condition section above were part of the same population of 60 participants. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to retain documentation to evidence its compliance with program eligibility requirements for those documents which will not be retained in WIC WISE. We also recommend that the county strengthen its current policies and procedures with regards to obtaining the required forms at the initial application and periodic redeterminations. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: As a result of our procurement testing, we identified one (1) instance out of a population of one (1) where the County did not document the history of the procurement, including the rationale for method of procurement, selection of contract type, basis for contractor selection, and basis for the contract price. Cause: The County’s procurement policy and procedures do not comply with the uniform guidance requirements to obtain document the history of each procurement transaction. Effect: The County did not comply with the procurement, suspension and debarment requirements. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over procurement. We selected 100% of the procurements in the year under audit. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that the history of each procurement transaction. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Foster Care Federal Financial Assistance Listing No.: 93.658 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted two (2) out of 44 cases were incorrectly identified as federal eligible by the County. Cause: The County transitioned to the California Statewide Automated Welfare System (CalSAWS) in the fiscal year 2024. During this transition, the case was inadvertently converted to a federal case in error. Effect: The County did not comply with the eligibility requirements. Questioned Costs: Known questioned costs were $15,517. Projected questioned costs were $92,568. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 44 cases out of a population 221 were selected for testing. The sample represented $579,924 in benefits out of $2,036,487. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards reviewing cases for federal eligibility. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Foster Care Federal Financial Assistance Listing No.: 93.658 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. This includes internal controls to ensure that federal funds are used only for federally eligible cases. Condition: As a result of our allowable activities and allowed cost testing, we noted one (1) out of 60 benefit payments which was paid to an eligible participant for federal benefits. Cause: The County transitioned to the California Statewide Automated Welfare System (CalSAWS) in the fiscal year 2024. During this transition, the case was inadvertently converted to a federal case in error. Effect: The County did not comply with the allowed activities and allowable costs requirements. Questioned Costs: Known questioned costs were $1,319. Projected questioned costs were $25,151. Context/Sampling: The condition noted above was found during our testing procedures over allowable activities and allowed costs. A sample of 60 benefit payments out of a population 2,293 were selected for testing. Our sample represented benefit payments of $53,252 out of $2,036,487. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards reviewing cases for federal eligibility prior to authorizing payment of benefits. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.