Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
For one (1) of sixty-eight (68) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor.
Cause:
The County’s procedures did not consistently ensure that the review of timecards was documented.
Effect:
Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of sixty-eight (68) out of one thousand seven hundred eight (1,708) expenditures were tested, totaling $537,604 out of $4,554,560 of the federal program expenditures.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
For one (1) of sixty-eight (68) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor.
Cause:
The County’s procedures did not consistently ensure that the review of timecards was documented.
Effect:
Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of sixty-eight (68) out of one thousand seven hundred eight (1,708) expenditures were tested, totaling $537,604 out of $4,554,560 of the federal program expenditures.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
For one (1) of sixty-eight (68) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor.
Cause:
The County’s procedures did not consistently ensure that the review of timecards was documented.
Effect:
Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of sixty-eight (68) out of one thousand seven hundred eight (1,708) expenditures were tested, totaling $537,604 out of $4,554,560 of the federal program expenditures.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
For one (1) of sixty-eight (68) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor.
Cause:
The County’s procedures did not consistently ensure that the review of timecards was documented.
Effect:
Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of sixty-eight (68) out of one thousand seven hundred eight (1,708) expenditures were tested, totaling $537,604 out of $4,554,560 of the federal program expenditures.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
For one (1) of sixty-eight (68) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor.
Cause:
The County’s procedures did not consistently ensure that the review of timecards was documented.
Effect:
Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of sixty-eight (68) out of one thousand seven hundred eight (1,708) expenditures were tested, totaling $537,604 out of $4,554,560 of the federal program expenditures.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For two (2) out of two (2) contracts selected for testing there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For two (2) out of two (2) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of two (2) contracts selected for testing with a contract value of $600,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of two (2) out of twelve (12) procurement contracts were tested. This represented a total of $2,285,000 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
Assistance Listing No.: 10.557
Federal Grantor: U.S. Department of Agriculture
Passed-through: California Department of Public Health
Award No.: 22-10307
Award Year: 2024
Compliance Requirement: Activities Allowable or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
For one (1) of sixty-eight (68) expenditures tested, we noted one timecard where the employee’s timecard was not approved by a supervisor.
Cause:
The County’s procedures did not consistently ensure that the review of timecards was documented.
Effect:
Lack of review for personnel hours could lead to unallowable activities and costs to be charged to the Federal program.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of sixty-eight (68) out of one thousand seven hundred eight (1,708) expenditures were tested, totaling $537,604 out of $4,554,560 of the federal program expenditures.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend that the County modify and/or strengthen its current policies and procedures to ensure that all timecards consistently document evidence of supervisor approval. The procedures should also address the compensating controls for circumstances where obtaining the supervisor’s approval is not possible.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Condition:
For two (2) out of two (2) financial summary reports CDBG PR26 and CDBG-CV PR26, the County did not retain evidence to document the individual who reviewed and approved the required reports.
Cause:
The County’s procedures did not include documenting the review and approval of the reports prior to submission.
Effect:
Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
A non-statistical sample of two (2) out of two (2) financial summary reports were selecting for testing. The condition above was identified during our procedures over reporting testing.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirements: Reporting
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Condition:
As a result of our audit procedures, we noted that five (5) out of five (5) first tier sub-awards tested were not reported timely in the FFATA Subaward Reporting System (FSRS), totaling $1,823,318. We also noted there was no review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions.
Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
5 - 5 - -
Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements
$1,823,318 - $1,823,318 - -
Cause:
The County did not have proper internal controls in place to ensure sub-award information was submitted timely in accordance with the FFATA. We also noted there was no review of the FFATA submissions by an individual independent of the FFATA submissions.
Effect:
Subaward obligations were not reported in the FSRS on a timely basis.
Questioned Costs:
No questioned costs were identified as a result of our audit procedures.
Context/Sampling:
We tested the entire population of five subawards obligations during the year.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure subaward information is reviewed by management and submitted timely in accordance with the FFATA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: CDBG-Entitlement/Special Purpose Grants Cluster
Assistance Listing No.: 14.218
Federal Grantor: U.S. Department of Housing and Urban Development
Passed-through: Direct Award and Pass-Through City of San Buenaventura
Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, 95-6000807
Award Year: 2024
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
In accordance with the 2024 OMB Compliance Supplement, nonfederal entities must record expenditures on the Schedule of Expenditures of Federal Awards (SEFA). The SEFA must include the total amount provided to subrecipients from each Federal program, on a cash basis.
In addition, section 200.303 of the Uniform Guidance states that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA we noted subrecipient expenditures totaling $654,123 for the CDBG-Entitlement/Special Purpose Grants Cluster were incorrectly included on the SEFA as these expenditures were not paid until after June 30, 2024.
Cause:
County did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA.
Effect:
Prior to correction, amounts passed through to subrecipients for the CDBG-Entitlement/Special Purpose Grants Cluster on the SEFA were overstated by $654,123.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used. Program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Crime Victim Assistance
Assistance Listing No.: 16.575
Federal Grantor: U.S. Department of Justice
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 16.575 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Crime Victim Assistance program we noted the County initially reported expenditures totaling $1,491,417 that should have been reported on the FY 2023 SEFA, as the County incurred the expenditures prior to June 30, 2023. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not have adequate internal controls to ensure the Schedule was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Crime Victim Assistance program were overstated by $1,491,417. We noted the FY 2023 expenditures incorrectly reported on the FY 2024 SEFA did not have a direct and material effect on the FY 2023 SEFA.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We the recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Health Center Program Cluster
Assistance Listing No.: 93.224; 93.527
Federal Grantor: U.S. Department of Health and Human Services
Passed-through: N/A
Award No.: 4 H8GCS48295‐01‐01
Award Year: 12/01/2022 ‐ 12/31/2023
Compliance Requirement: Procurement and Suspension and Debarment
Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance
Criteria:
2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity.
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.
2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
Condition:
During our testing of the County’s provisions for procurement requirements, we noted the following:
1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract.
2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II.
3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
Cause:
The County did not follow their policy to verify the information described in the condition prior to entering the transactions.
The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price.
The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts.
Effect:
Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: County of El Dorado, California
Award No.: FEMA 5302-FM-CA, LEMA
Award Year: 2024
Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria:
2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable and properly allocated.
Condition:
During our testing of the County’s compliance with activities allowed or unallowed and allowable costs/cost principles requirements, we noted that seven (7) out of fifty (50) expenditure transactions were calculated incorrectly, resulting in total known disallowed costs of $474,776.
Cause:
The County did not have internal controls in place to ensure that the salaries claimed for reimbursement were being calculated correctly.
Effect:
The County submitted salaries and benefits for reimbursement for the California Caldor Fire incident. The amount of salaries and benefits claimed for reimbursement was overstated by $474,776.
Questioned Costs:
Our testing resulted in questioned costs in the amount of $9,344. However, management determined the total known questioned costs for the total population was $474,776.
Context/Sampling:
A nonstatistical sample of fifty (50) expenditure transactions were selected for testing out of a population of 1,063.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County implement internal controls to ensure all costs charged to the programs are calculated correctly in accordance with the program requirement, and that there is proper review and approval.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters)
Assistance Listing No.: 97.036
Federal Grantor: U.S. Department of Homeland Security
Passed-through: California Governor's Office of Emergency Services
Award No. and Year: Affects all grant awards included under assistance listing 97.036 on the
Schedule of Expenditures of Federal Awards.
Compliance Requirement: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of Expenditures of Federal Awards
Type of Finding: Material Weakness in Internal Control Over Compliance
Criteria:
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended (including amounts provided to subrecipients) as determined in accordance with §200.502.
In addition, section 200.303 of the Uniform Guidance state that that recipients and subrecipients must establish effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts.
Condition:
During our audit procedures performed over the SEFA and expenditures reported for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program we noted the County understated expenditures totaling $1,188,371. The June 30, 2024 SEFA was corrected for this reporting error.
Cause:
The County did not report two Disaster Grants – Public Assistance (Presidentially Declared Disasters) program grants on the SEFA, that were approved by the granting agency during the fiscal year ended June 30, 2024. The County did not have adequate internal controls to ensure the SEFA was prepared completely and accurately.
Effect:
Prior to the correction, expenditures for the Disaster Grants – Public Assistance (Presidentially Declared Disasters) program were understated by $1,188,370.
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
No sampling was used; all program expenditures on the SEFA were reconciled to supporting records.
Repeat Finding from Prior Years:
No.
Recommendation:
We recommend the County enhance internal controls to ensure federal expenditures are reported accurately and completely on the SEFA in accordance with the OMB Uniform Guidance.
Views of Responsible Officials:
Management agrees. See separately issued Corrective Action Plan.