FINDING 2024-001
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY 2024
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
INDIANA STATE BOARD OF ACCOUNTS
13
WHITLEY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2023-003.
Condition and Context
The County received a total COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) allocation
of $6,597,109 and chose to calculate its own revenue loss amount, which exceeded the County's full
allocation amount, thus, enabling them to use up to the full amount for government services. All SLFRF
program funds expended to date have been expended under the revenue loss eligible use category. The
U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use
category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships
given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the
award.
Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are
required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise
excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded
under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000.
The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification
from that person or entity, or adding a clause or condition to the covered transaction with that person or
entity. Due to the Treasury's determination that the revenue loss eligible use category does not give rise
to subawards, the County was only required to comply with suspension and debarment requirements
related to covered transactions.
Upon inquiry of the County's policies and procedures related to suspension and debarment
requirements, the County disclosed its process is for the County Attorney to review agreements or contracts
to ensure that they include language related to suspension and debarment but that there were no processes
in place during the audit period to verify the suspension and debarment status of vendors which did not
have written contracts in place with the County.
Two covered transactions for goods or services that equaled or exceeded $25,000 that were paid
from SLFRF funds during the audit period were selected for testing. The two covered transactions selected
totaled $60,210. Each transaction was examined to determine whether the County verified the suspension
and debarment status of the vendor prior to payment. Based on inquiry with the County, we determined
that neither vendor had a written contract in place. The County did not otherwise verify vendors were
neither suspended nor debarred or excluded or disqualified from participating in federal assistance
programs or activities prior to payment.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
INDIANA STATE BOARD OF ACCOUNTS
14
WHITLEY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
31 CFR 19.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you do business is not excluded or disqualified. You do this
by:
(a) Checking the EPLS; or
(b) Collecting a certification from that person if allowed by this rule; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
After a previous Indiana State Board of Accounts audit, the County established procedures to
include a suspension and debarment clause in agreements or contracts; however, it did not establish
procedures to verify the suspension and debarment status of vendors which did not have written contracts
in place with the County because the County was unaware of this requirement.
Effect
Without the proper implementation of an effectively designed system of internal controls, the
County cannot ensure the contractors paid with federal funds are eligible to participate in federal programs.
Any program funds the County used to pay contractors that have been suspended or debarred would be
unallowable, and the funding agency could potentially recover them.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County strengthen its system of internal controls to
ensure that all covered transactions exceeding $25,000 or more, all or in part with federal funds, are not
suspended, debarred, or otherwise excluded from participating in federal programs prior to entering into
any contracts.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY 2024
Pass-Through Entity: Indiana Department of Health
Compliance Requirement: Reporting
Audit Finding: Material Weakness
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2023-002.
Condition and Context
Recipients are required to submit program invoices to the Indiana Department of Health (IDOH) via
email. Information to be reported includes, but is not limited to, the number of cases performed during the
grant's period of performance.
The County submitted one program invoice as required during the audit period; however, there
were no internal controls in place that would likely be effective in preventing, or detecting and correcting,
noncompliance related to the reporting requirements. The program invoices were prepared and submitted
by one employee without an oversight, review, or approval process to ensure accuracy and completeness.
The lack of internal controls over program invoices was a systemic issue throughout the audit
period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
Cause
A proper system of internal controls was not designed and implemented by management of the
County, which would include segregation of key functions. Embedded within a properly designed and
implemented internal control system should be internal controls consisting of policies and procedures.
Policies reflect the County's management statements of what should be done to effect internal controls,
and procedures should consist of actions that would implement these policies.
INDIANA STATE BOARD OF ACCOUNTS
16
WHITLEY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
Without the proper implementation of an effectively designed system of internal controls over
reporting, the County cannot ensure that the reports submitted are materially accurate and correct.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County design and implement a proper system of
internal controls, including policies and procedures to ensure that the County provides the IDOH with
complete and accurate information for the program invoices.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-001
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY 2024
Compliance Requirement: Procurement and Suspension and Debarment
Audit Findings: Material Weakness, Modified Opinion
INDIANA STATE BOARD OF ACCOUNTS
13
WHITLEY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2023-003.
Condition and Context
The County received a total COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) allocation
of $6,597,109 and chose to calculate its own revenue loss amount, which exceeded the County's full
allocation amount, thus, enabling them to use up to the full amount for government services. All SLFRF
program funds expended to date have been expended under the revenue loss eligible use category. The
U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use
category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships
given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the
award.
Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are
required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise
excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded
under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000.
The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification
from that person or entity, or adding a clause or condition to the covered transaction with that person or
entity. Due to the Treasury's determination that the revenue loss eligible use category does not give rise
to subawards, the County was only required to comply with suspension and debarment requirements
related to covered transactions.
Upon inquiry of the County's policies and procedures related to suspension and debarment
requirements, the County disclosed its process is for the County Attorney to review agreements or contracts
to ensure that they include language related to suspension and debarment but that there were no processes
in place during the audit period to verify the suspension and debarment status of vendors which did not
have written contracts in place with the County.
Two covered transactions for goods or services that equaled or exceeded $25,000 that were paid
from SLFRF funds during the audit period were selected for testing. The two covered transactions selected
totaled $60,210. Each transaction was examined to determine whether the County verified the suspension
and debarment status of the vendor prior to payment. Based on inquiry with the County, we determined
that neither vendor had a written contract in place. The County did not otherwise verify vendors were
neither suspended nor debarred or excluded or disqualified from participating in federal assistance
programs or activities prior to payment.
The lack of internal controls and noncompliance were systemic issues throughout the audit period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
INDIANA STATE BOARD OF ACCOUNTS
14
WHITLEY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
31 CFR 19.300 states:
"When you enter into a covered transaction with another person at the next lower tier, you must
verify that the person with whom you do business is not excluded or disqualified. You do this
by:
(a) Checking the EPLS; or
(b) Collecting a certification from that person if allowed by this rule; or
(c) Adding a clause or condition to the covered transaction with that person."
Cause
After a previous Indiana State Board of Accounts audit, the County established procedures to
include a suspension and debarment clause in agreements or contracts; however, it did not establish
procedures to verify the suspension and debarment status of vendors which did not have written contracts
in place with the County because the County was unaware of this requirement.
Effect
Without the proper implementation of an effectively designed system of internal controls, the
County cannot ensure the contractors paid with federal funds are eligible to participate in federal programs.
Any program funds the County used to pay contractors that have been suspended or debarred would be
unallowable, and the funding agency could potentially recover them.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County strengthen its system of internal controls to
ensure that all covered transactions exceeding $25,000 or more, all or in part with federal funds, are not
suspended, debarred, or otherwise excluded from participating in federal programs prior to entering into
any contracts.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2024-002
Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting
Federal Agency: Department of the Treasury
Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds
Assistance Listings Number: 21.027
Federal Award Number and Year (or Other Identifying Number): FY 2024
Pass-Through Entity: Indiana Department of Health
Compliance Requirement: Reporting
Audit Finding: Material Weakness
Repeat Finding
This is a repeat finding from the immediately prior audit report. The prior audit finding number was
2023-002.
Condition and Context
Recipients are required to submit program invoices to the Indiana Department of Health (IDOH) via
email. Information to be reported includes, but is not limited to, the number of cases performed during the
grant's period of performance.
The County submitted one program invoice as required during the audit period; however, there
were no internal controls in place that would likely be effective in preventing, or detecting and correcting,
noncompliance related to the reporting requirements. The program invoices were prepared and submitted
by one employee without an oversight, review, or approval process to ensure accuracy and completeness.
The lack of internal controls over program invoices was a systemic issue throughout the audit
period.
Criteria
2 CFR 200.303 states in part:
"The non-Federal entity must:
(a) 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. These internal controls should be in compliance with guidance in 'Standards for
Internal Control in the Federal Government' issued by the Comptroller General of the
United States or the 'Internal Control Integrated Framework', issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO). . . ."
Cause
A proper system of internal controls was not designed and implemented by management of the
County, which would include segregation of key functions. Embedded within a properly designed and
implemented internal control system should be internal controls consisting of policies and procedures.
Policies reflect the County's management statements of what should be done to effect internal controls,
and procedures should consist of actions that would implement these policies.
INDIANA STATE BOARD OF ACCOUNTS
16
WHITLEY COUNTY
SCHEDULE OF FINDINGS AND QUESTIONED COSTS
(Continued)
Effect
Without the proper implementation of an effectively designed system of internal controls over
reporting, the County cannot ensure that the reports submitted are materially accurate and correct.
Questioned Costs
There were no questioned costs identified.
Recommendation
We recommended that management of the County design and implement a proper system of
internal controls, including policies and procedures to ensure that the County provides the IDOH with
complete and accurate information for the program invoices.
Views of Responsible Officials
For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.