2024-002 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Programs: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
Award Number and Year: 242MN101S2514, 242MN101S2520, 242MN127Q7503; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 16 covered transactions during the year using State Administrative Matching Grants for the Supplemental Nutrition Assistance Program funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County did not anticipate paying for these expenditures using federal funds and therefore did not perform or document the search for suspension and debarment.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-002 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Programs: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
Award Number and Year: 242MN101S2514, 242MN101S2520, 242MN127Q7503; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 16 covered transactions during the year using State Administrative Matching Grants for the Supplemental Nutrition Assistance Program funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County did not anticipate paying for these expenditures using federal funds and therefore did not perform or document the search for suspension and debarment.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-002 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Programs: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
Award Number and Year: 242MN101S2514, 242MN101S2520, 242MN127Q7503; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 16 covered transactions during the year using State Administrative Matching Grants for the Supplemental Nutrition Assistance Program funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County did not anticipate paying for these expenditures using federal funds and therefore did not perform or document the search for suspension and debarment.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-003 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of the Treasury
Programs: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Award Number and Year: SLFRP0278; 2021
Pass-Through Agency: N/A - Direct
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 36 covered transactions during the year using COVID-19 – Coronavirus State and Local Fiscal Recovery Funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County informed us that, for one covered transaction, the County did not retain results of the suspension and debarment search, and, for one covered transaction, the County did not initially anticipate using federal funds to pay for the transaction.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-004 Eligibility
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Program: 93.558 Temporary Assistance for Needy Families
Award Number and Year: 2401MNTANF; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Title 42 United States Code § 602(a)(1)(B)(iii) requires each state to create a plan for the delivery of benefits and the determination of eligibility. The Minnesota Department of Human Services’ State Plan for Temporary Assistance for Needy Families (TANF) and Minn. Stat. § 142G.10 establish the general eligibility requirements for TANF benefits which require the county to document, verify, and recertify specific information, including information relating to assets and income.
Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by Anoka County to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation was available, updated, or input correctly to support participant eligibility. The following exceptions were noted in the sample of 40 MAXIS case files tested:
• Two case files had assets in MAXIS that were not updated to agree with supporting documentation in the case file.
• One case file did not have the support for the income listed in MAXIS.
• One case file did not have the support for the assets listed in MAXIS.
• One case file transferred from another agency did not include the supporting documentation to verify compliance.
Questioned Costs: Not applicable. The County administers the program, but the State of Minnesota pays benefits to participants in this program.
Context: The State of Minnesota and the County split the eligibility determination process. Pursuant to Minnesota statutes, Anoka County performs the “intake function” needed for this program, while the state maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the state.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: The lack of updated information in MAXIS to document verification of key eligibility-determining factors increases the risk that program participants will receive benefits when they are not eligible.
Cause: Program personnel entering case data into MAXIS did not ensure all required information was retained in the case file as it was entered into MAXIS. The County did not retain specific information for one participant that moved into and out of the County.
Recommendation: We recommend Anoka County implement additional procedures to provide reasonable assurance that the information is properly input or updated in MAXIS and retained in the supporting case files.
View of Responsible Official: Concur
2024-002 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Programs: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
Award Number and Year: 242MN101S2514, 242MN101S2520, 242MN127Q7503; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 16 covered transactions during the year using State Administrative Matching Grants for the Supplemental Nutrition Assistance Program funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County did not anticipate paying for these expenditures using federal funds and therefore did not perform or document the search for suspension and debarment.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-002 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Programs: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
Award Number and Year: 242MN101S2514, 242MN101S2520, 242MN127Q7503; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 16 covered transactions during the year using State Administrative Matching Grants for the Supplemental Nutrition Assistance Program funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County did not anticipate paying for these expenditures using federal funds and therefore did not perform or document the search for suspension and debarment.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-002 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Programs: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program
Award Number and Year: 242MN101S2514, 242MN101S2520, 242MN127Q7503; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 16 covered transactions during the year using State Administrative Matching Grants for the Supplemental Nutrition Assistance Program funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County did not anticipate paying for these expenditures using federal funds and therefore did not perform or document the search for suspension and debarment.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-003 Suspension and Debarment
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of the Treasury
Programs: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Award Number and Year: SLFRP0278; 2021
Pass-Through Agency: N/A - Direct
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Federal requirements prohibit non-federal entities from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Title 2 U.S. Code of Federal Regulations § 180.300 describes a required verification process. Prior to entering into the transaction, one of the following must be performed: (1) checking SAM.gov exclusions, (2) collecting a certification, or (3) adding a clause or condition to the covered transaction.
Condition: For two of the four covered transactions tested, the County did not maintain documentation of verification that the vendors were not suspended or debarred prior to entering into the covered transactions.
Questioned Costs: None.
Context: The County entered into a total of 36 covered transactions during the year using COVID-19 – Coronavirus State and Local Fiscal Recovery Funds. The vendors tested that did not have documentation of verification prior to entering the transaction were not listed as suspended or debarred on SAM.gov at the time of the audit.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: Failure to verify vendors are not suspended, debarred, or otherwise excluded prior to entering into a covered transaction may result in the County entering into a transaction with a vendor that is not authorized to provide goods and services under the grant.
Cause: The County informed us that, for one covered transaction, the County did not retain results of the suspension and debarment search, and, for one covered transaction, the County did not initially anticipate using federal funds to pay for the transaction.
Recommendation: We recommend the County maintain documentation to demonstrate that vendors were not debarred, suspended or otherwise excluded from conducting business with the County; this documentation should be completed prior to entering into a covered transaction.
View of Responsible Official: Concur
2024-004 Eligibility
Prior Year Finding Number: N/A
Year of Finding Origination: 2024
Type of Finding: Internal Control Over Compliance and Compliance
Severity of Deficiency: Significant Deficiency and Other Matter
Federal Agency: U.S. Department of Health and Human Services
Program: 93.558 Temporary Assistance for Needy Families
Award Number and Year: 2401MNTANF; 2024
Pass-Through Agency: Minnesota Department of Human Services
Criteria: Title 2 U.S. Code of Federal Regulations § 200.303 states that the auditee must establish and maintain effective internal control over the federal award that provides reasonable assurance that the auditee is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.
Title 42 United States Code § 602(a)(1)(B)(iii) requires each state to create a plan for the delivery of benefits and the determination of eligibility. The Minnesota Department of Human Services’ State Plan for Temporary Assistance for Needy Families (TANF) and Minn. Stat. § 142G.10 establish the general eligibility requirements for TANF benefits which require the county to document, verify, and recertify specific information, including information relating to assets and income.
Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by Anoka County to support the eligibility determination process. In the case files reviewed for eligibility, not all documentation was available, updated, or input correctly to support participant eligibility. The following exceptions were noted in the sample of 40 MAXIS case files tested:
• Two case files had assets in MAXIS that were not updated to agree with supporting documentation in the case file.
• One case file did not have the support for the income listed in MAXIS.
• One case file did not have the support for the assets listed in MAXIS.
• One case file transferred from another agency did not include the supporting documentation to verify compliance.
Questioned Costs: Not applicable. The County administers the program, but the State of Minnesota pays benefits to participants in this program.
Context: The State of Minnesota and the County split the eligibility determination process. Pursuant to Minnesota statutes, Anoka County performs the “intake function” needed for this program, while the state maintains the MAXIS system, which supports the eligibility determination process. Participants receive benefit payments from the state.
The sample size was based on guidance from Chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits.
Effect: The lack of updated information in MAXIS to document verification of key eligibility-determining factors increases the risk that program participants will receive benefits when they are not eligible.
Cause: Program personnel entering case data into MAXIS did not ensure all required information was retained in the case file as it was entered into MAXIS. The County did not retain specific information for one participant that moved into and out of the County.
Recommendation: We recommend Anoka County implement additional procedures to provide reasonable assurance that the information is properly input or updated in MAXIS and retained in the supporting case files.
View of Responsible Official: Concur