Audit 366181

Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 228MN300S6031 – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55210010 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Agencies are required to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP (7 CFR sections 272.10 and 277.18). This includes: (1) processing and storing all case file information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation for households that have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period (7 CFR sections 272.10(b)(1)(iii) and 273.10(f) and (g)); and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. 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. Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted: • There was no documentation or improper documentation related to the verification of citizenship for 6 of the 60 casefiles tested. • There was no verification of income on 3 of the 60 casefiles tested. • Income was input into Maxis incorrectly on 2 of the 60 casefiles tested. • There was not signature on application on 1 of the 60 casefiles tested. Questioned costs: None Context: 11 of the 60 casefiles tested had the above noted issues. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: Yes – 2022-004 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 228MN300S6031 – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The County must follow Uniform Guidance Subsection 200.320 Methods of Procurement for all applicable procurements over the County’s micro-purchase threshold. For purchases over the County's micro-purchase threshold of $10,000 but not exceeding the simplified acquisition threshold of $250,000, the County should follow small purchase procedures. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the County. 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. Condition: During our testing, it was noted that for 2 contracts out of 4 tested the County was unable to provide documentation showing they contract awards followed the open competition requirement. Questioned costs: None Context: 2 out of the 4 contracts tested had no documentation of open competition. Cause: The county purchasing likely followed county purchase policies for non-federal expenditures. Effect: It would be possible that the County could end up spending more federal dollars than necessary for a product or service, if they are not going through the steps to ensure they are utilizing the best vendor for the county and documenting this process each year. Repeat finding: No Recommendation: We recommend the County follow their federal purchasing policy in all of their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are program specific to ensure this properly occurs. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3412 - 2023 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Related to subrecipient monitoring requirements of State and Local Fiscal Recovery Funds, there should be a documented control in place to ensure all subrecipients of federal grants are in compliance with Title 2 U.S. Code of Federal Regulations § 200.331 - 200.333. 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. Condition: During our testing it was noted that, for 1 of 1 subrecipients tested, the county was not able to provide any documentation of the review performed to ensure they are meeting federal requirements surrounding subrecipient monitoring. Questioned costs: None Context: 1 of 1 subrecipients selected for testing were missing documentation. Cause: The County has a monitoring checklist they complete, but did not have adequate documentation that it was completed. Effect: It is possible that the County subrecipient could be ineligible to receive funding if an error is made in compiling the information since there is no control in place in some instances to ensure that errors are not being made prior to payment. Repeat finding: No Recommendation: We recommend that the County establish clear policies and procedures for formal review and approval of subrecipient monitoring checklists. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Identification Number and Year: 2201MNTANF – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55214077 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 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. The State provides the specifics on the definition of need, which the State and County uses in determining eligibility. Casefiles and related computer systems must be accurately maintained to support eligibility determinations. Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted that not all documentation was available to support participant eligibility. In other circumstances, information was either input incorrectly or not properly updated in MAXIS. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. The following instances were noted in sample of 60 cases tested: • 9 of 60 casefiles selected for testing had citizenship selected as yes, but had no support retained to prove that citizenship verification had occurred. • 3 of 60 casefiles selected for testing had citizenship verified by driver’s license which is not a valid method of determining citizenship. • 8 of 60 casefiles selected for testing did not have verified worker approval of annual eligibility certification documentation on file. • 12 of 60 casefiles selected for testing had various inconsistencies between what was shown on MAXIS for income or assets and what was provided as testing support in the casefile to State’s eligibility requirements for TANF as provided in the State plan, including being "needy." Questioned costs: None Context: The context of the variance instances noted in the 60 case files tested is summarized above. Note that, of the 60 case files tested, there were a total of 32 instances that were part of 30 casefiles. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: Yes – 2022-003 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Identification Number and Year: 2201MNTANF – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55214077 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 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. The State provides the specifics on the definition of need, which the State and County uses in determining eligibility. Casefiles and related computer systems must be accurately maintained to support eligibility determinations. Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted that not all documentation was available to support participant eligibility. In other circumstances, information was either input incorrectly or not properly updated in MAXIS. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. The following instances were noted in sample of 60 cases tested: • 9 of 60 casefiles selected for testing had citizenship selected as yes, but had no support retained to prove that citizenship verification had occurred. • 3 of 60 casefiles selected for testing had citizenship verified by driver’s license which is not a valid method of determining citizenship. • 8 of 60 casefiles selected for testing did not have verified worker approval of annual eligibility certification documentation on file. • 12 of 60 casefiles selected for testing had various inconsistencies between what was shown on MAXIS for income or assets and what was provided as testing support in the casefile to State’s eligibility requirements for TANF as provided in the State plan, including being "needy." Questioned costs: None Context: The context of the variance instances noted in the 60 case files tested is summarized above. Note that, of the 60 case files tested, there were a total of 32 instances that were part of 30 casefiles. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: Yes – 2022-003 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2305MNMAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Minnesota Department of Human Services (DHS) requires a listing of employees working on social services programs to be submitted quarterly, known as a random moment study listing (RMS listing). DHS then determines the amount applicable to the applicable income maintenance programs through random moment studies. Each quarter the County’s coordinator reviews their RMS listing to ensure the employees listed are accurate for the people working and being coded in the general ledger. 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. Condition: 7 individuals were included on the 1st quarter Social Services RMS listing sent to the State that were not supposed to be included in the listings, 7 individuals were noted to have the same issue on the 4th quarter Social Services RMS listing. Questioned costs: None Context: In our testing of 2 of the 4 quarterly RMS listings, 7 individuals were included on the 1st quarter RMS listing sent to the State that were not supposed to be included in the listings, 7 individuals were noted to have the same issue on the 4th quarter RMS listing. There were 302 County staff listed in the 1st quarter’s RMS listing and 306 County staff listed in the 4th quarter’s RMS listing. Cause: The County's RMS controls and procedures were not robust enough to note that the RMS listings should have excluded various individuals. Increased turnover and growth of the programs also created an increase in the number changes that were needed to be made to the listings. Effect: Lack of proper controls could affect allocation of fundings due to the staff not being in MAXIS or actually assigned to social services case files to properly respond to the random moment requests that are sent by the State as part of the random moment study. Repeat Finding: No Recommendation: We recommend that the County review its procedures and control to ensure all RMS listings sent to the State properly exclude those necessary individuals no longer working in the programs. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2305MN5MAP – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Agencies are required to automate their MA operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning MA (7 CFR sections 272.10 and 277.18). This includes: (1) processing and storing all case file information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation for households that have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period (7 CFR sections 272.10(b)(1)(iii) and 273.10(f) and (g)); and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. 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. Condition: One of the casefiles was approved utilizing an unsigned application for July where it was noted that the application was signed. There was a signed application in September for this individual, however the MAXIS system showed that the application was signed and dated in July. The second issue noted was for eligibility for adoption assistance that didn’t have any casefile documentation that it was reviewed during the year for eligibility. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Questioned costs: None Context: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted issues related to 2 of the 40 Maxis Individuals Tested. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: No Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 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. The County and the Minnesota Department of Human Services (DHS) have a contract surrounding the federal funds. This contract has several obligations and reporting requirements the County must follow. Condition: • The County was unable to provide documented formal review or approval of the LCTS Annual Spending Report. • The County was unable to provide documented formal review or approval of the quarterly cost reports. • The County was unable to provide a documented formal review process to ensure that LCTS fiscal site contacts were trained on completing cost schedules. Questioned costs: None Context: The County did not provide the documentation of the review over these requirements. Cause: The County did not maintain a record of their review process Effect: There is no way to verify the review process was completed and completed timely. Repeat finding: No Recommendation: We recommend that the County review its policies and controls to ensure there is a formally documented control to ensure all reports are reviewed and the documentation of the review is retained. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 228MN300S6031 – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55210010 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Agencies are required to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP (7 CFR sections 272.10 and 277.18). This includes: (1) processing and storing all case file information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation for households that have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period (7 CFR sections 272.10(b)(1)(iii) and 273.10(f) and (g)); and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. 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. Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted: • There was no documentation or improper documentation related to the verification of citizenship for 6 of the 60 casefiles tested. • There was no verification of income on 3 of the 60 casefiles tested. • Income was input into Maxis incorrectly on 2 of the 60 casefiles tested. • There was not signature on application on 1 of the 60 casefiles tested. Questioned costs: None Context: 11 of the 60 casefiles tested had the above noted issues. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: Yes – 2022-004 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture Federal Program Name: Supplemental Nutrition Assistance Program Cluster Assistance Listing Number: 10.561 Federal Award Identification Number and Year: 228MN300S6031 – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The County must follow Uniform Guidance Subsection 200.320 Methods of Procurement for all applicable procurements over the County’s micro-purchase threshold. For purchases over the County's micro-purchase threshold of $10,000 but not exceeding the simplified acquisition threshold of $250,000, the County should follow small purchase procedures. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the County. 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. Condition: During our testing, it was noted that for 2 contracts out of 4 tested the County was unable to provide documentation showing they contract awards followed the open competition requirement. Questioned costs: None Context: 2 out of the 4 contracts tested had no documentation of open competition. Cause: The county purchasing likely followed county purchase policies for non-federal expenditures. Effect: It would be possible that the County could end up spending more federal dollars than necessary for a product or service, if they are not going through the steps to ensure they are utilizing the best vendor for the county and documenting this process each year. Repeat finding: No Recommendation: We recommend the County follow their federal purchasing policy in all of their federal programs and retain documentation of that process occurring. As necessary, the County may need to add internal controls that are program specific to ensure this properly occurs. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 693JJ22330000Y300MN1921048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. Questioned costs: None Context: During our testing it was noted that, for 1 of the 5 the contracts tested County did not receive or verify the contract was in compliance with prevailing wage compliance requirements. It was being completed by a third party vendor, but the county did not receive documentation verifying it was being completed. Cause: The County did not request or retain the documentation of this requirement being met. Effect: It is possible that the County could be out of compliance with prevailing wage rate requirements. Repeat finding: No Recommendation: We recommend the County implement a internal controls to verify they are compliant with prevailing wage requirements when a consultant is used. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP3412 - 2023 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Related to subrecipient monitoring requirements of State and Local Fiscal Recovery Funds, there should be a documented control in place to ensure all subrecipients of federal grants are in compliance with Title 2 U.S. Code of Federal Regulations § 200.331 - 200.333. 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. Condition: During our testing it was noted that, for 1 of 1 subrecipients tested, the county was not able to provide any documentation of the review performed to ensure they are meeting federal requirements surrounding subrecipient monitoring. Questioned costs: None Context: 1 of 1 subrecipients selected for testing were missing documentation. Cause: The County has a monitoring checklist they complete, but did not have adequate documentation that it was completed. Effect: It is possible that the County subrecipient could be ineligible to receive funding if an error is made in compiling the information since there is no control in place in some instances to ensure that errors are not being made prior to payment. Repeat finding: No Recommendation: We recommend that the County establish clear policies and procedures for formal review and approval of subrecipient monitoring checklists. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Identification Number and Year: 2201MNTANF – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55214077 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 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. The State provides the specifics on the definition of need, which the State and County uses in determining eligibility. Casefiles and related computer systems must be accurately maintained to support eligibility determinations. Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted that not all documentation was available to support participant eligibility. In other circumstances, information was either input incorrectly or not properly updated in MAXIS. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. The following instances were noted in sample of 60 cases tested: • 9 of 60 casefiles selected for testing had citizenship selected as yes, but had no support retained to prove that citizenship verification had occurred. • 3 of 60 casefiles selected for testing had citizenship verified by driver’s license which is not a valid method of determining citizenship. • 8 of 60 casefiles selected for testing did not have verified worker approval of annual eligibility certification documentation on file. • 12 of 60 casefiles selected for testing had various inconsistencies between what was shown on MAXIS for income or assets and what was provided as testing support in the casefile to State’s eligibility requirements for TANF as provided in the State plan, including being "needy." Questioned costs: None Context: The context of the variance instances noted in the 60 case files tested is summarized above. Note that, of the 60 case files tested, there were a total of 32 instances that were part of 30 casefiles. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: Yes – 2022-003 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Identification Number and Year: 2201MNTANF – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Number: H55214077 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 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. The State provides the specifics on the definition of need, which the State and County uses in determining eligibility. Casefiles and related computer systems must be accurately maintained to support eligibility determinations. Condition: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted that not all documentation was available to support participant eligibility. In other circumstances, information was either input incorrectly or not properly updated in MAXIS. The sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. The following instances were noted in sample of 60 cases tested: • 9 of 60 casefiles selected for testing had citizenship selected as yes, but had no support retained to prove that citizenship verification had occurred. • 3 of 60 casefiles selected for testing had citizenship verified by driver’s license which is not a valid method of determining citizenship. • 8 of 60 casefiles selected for testing did not have verified worker approval of annual eligibility certification documentation on file. • 12 of 60 casefiles selected for testing had various inconsistencies between what was shown on MAXIS for income or assets and what was provided as testing support in the casefile to State’s eligibility requirements for TANF as provided in the State plan, including being "needy." Questioned costs: None Context: The context of the variance instances noted in the 60 case files tested is summarized above. Note that, of the 60 case files tested, there were a total of 32 instances that were part of 30 casefiles. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: Yes – 2022-003 Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2305MNMAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: The Minnesota Department of Human Services (DHS) requires a listing of employees working on social services programs to be submitted quarterly, known as a random moment study listing (RMS listing). DHS then determines the amount applicable to the applicable income maintenance programs through random moment studies. Each quarter the County’s coordinator reviews their RMS listing to ensure the employees listed are accurate for the people working and being coded in the general ledger. 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. Condition: 7 individuals were included on the 1st quarter Social Services RMS listing sent to the State that were not supposed to be included in the listings, 7 individuals were noted to have the same issue on the 4th quarter Social Services RMS listing. Questioned costs: None Context: In our testing of 2 of the 4 quarterly RMS listings, 7 individuals were included on the 1st quarter RMS listing sent to the State that were not supposed to be included in the listings, 7 individuals were noted to have the same issue on the 4th quarter RMS listing. There were 302 County staff listed in the 1st quarter’s RMS listing and 306 County staff listed in the 4th quarter’s RMS listing. Cause: The County's RMS controls and procedures were not robust enough to note that the RMS listings should have excluded various individuals. Increased turnover and growth of the programs also created an increase in the number changes that were needed to be made to the listings. Effect: Lack of proper controls could affect allocation of fundings due to the staff not being in MAXIS or actually assigned to social services case files to properly respond to the random moment requests that are sent by the State as part of the random moment study. Repeat Finding: No Recommendation: We recommend that the County review its procedures and control to ensure all RMS listings sent to the State properly exclude those necessary individuals no longer working in the programs. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2305MN5MAP – 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Agencies are required to automate their MA operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning MA (7 CFR sections 272.10 and 277.18). This includes: (1) processing and storing all case file information necessary for eligibility determination and benefit calculation, identifying specific elements that affect eligibility, and notifying the certification unit of cases requiring notices of case disposition, adverse action and mass change, and expiration; (2) providing an automatic cutoff of participation for households that have not been recertified at the end of their certification period by reapplying and being determined eligible for a new period (7 CFR sections 272.10(b)(1)(iii) and 273.10(f) and (g)); and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. 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. Condition: One of the casefiles was approved utilizing an unsigned application for July where it was noted that the application was signed. There was a signed application in September for this individual, however the MAXIS system showed that the application was signed and dated in July. The second issue noted was for eligibility for adoption assistance that didn’t have any casefile documentation that it was reviewed during the year for eligibility. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Questioned costs: None Context: The Minnesota Department of Human Services (DHS) maintains the computer system, MAXIS, which is used by the County to support the eligibility determination process. While periodic supervisory case reviews are performed to monitor compliance with grant requirements for eligibility, when performing our case file review for eligibility, we noted issues related to 2 of the 40 Maxis Individuals Tested. Cause: The County has had significant turnover and new staff over the past three years as well as increases in caseloads. There was also changing guidance as waivers from the pandemic expired. All of this provided more opportunities for errors to occur. Effect: Improper input or updating of information in MAXIS and lack of verification or follow-up of eligibility determining factors increase the risk that a program participant will receive benefits when they are not eligible. Repeat finding: No Recommendation: We recommend the County implement process and procedures to provide reasonable assurance that all necessary documentation to support eligibility determination exists and is properly input or updated in MAXIS and issues are followed up in a timely manner. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: 2 of 40 disbursements selected for testing lacked formal documentation of review and approval. Questioned costs: None Context: Lack of formal documentation of review and approval was noted with 2 of 40 disbursements selected for testing. Cause: At the time of testing, due to the cost allocation plan using a 2-year lag and then the audit occurring after year end, the item selected for testing was from about 3 years ago, and the County did not retain the supporting documentation of review and approval. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: Yes – 2022-0007 Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Assistance Listing Numbers: 93.778 Federal Award Identification Numbers and Years: 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55215048 Award Period: 2023 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Criteria or specific requirement: 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. The County and the Minnesota Department of Human Services (DHS) have a contract surrounding the federal funds. This contract has several obligations and reporting requirements the County must follow. Condition: • The County was unable to provide documented formal review or approval of the LCTS Annual Spending Report. • The County was unable to provide documented formal review or approval of the quarterly cost reports. • The County was unable to provide a documented formal review process to ensure that LCTS fiscal site contacts were trained on completing cost schedules. Questioned costs: None Context: The County did not provide the documentation of the review over these requirements. Cause: The County did not maintain a record of their review process Effect: There is no way to verify the review process was completed and completed timely. Repeat finding: No Recommendation: We recommend that the County review its policies and controls to ensure there is a formally documented control to ensure all reports are reviewed and the documentation of the review is retained. Views of responsible officials: There is no disagreement with the finding.

Federal Agency: U.S. Department of Agriculture & U.S. Department of Health and Human Services Federal Program Name: Supplemental Nutrition Assistance Program Cluster, Temporary Assistance for Needy Families, & Medical Assistance Assistance Listing Numbers: 10.561, 93.558, and 93.778 Federal Award Identification Numbers and Years: 228MN300S6031 – 2023, 2201MNTANF – 2023, 2305MN5MAP - 2023 Passed Through Entity: Minnesota Department of Human Services Pass Through Numbers: H55230010, H55214077, H55215048 Award Period: 2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Costs included in the County’s Cost Allocation Plan should follow the principles to establish allowability or unallowability of certain items of cost (2 CFR sections 200.420 through 200.476), including retention of supporting documentation and documentation of the related controls. 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. Condition: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Questioned costs: None Context: Building depreciation on the Cost Allocation Plan was overstated and did not agree to the actual building depreciation. Cause: The County did not adequately review the Cost Allocation Plan which was prepared by a third party vendor. Effect: Lack of proper controls result in error or unintended expenditures that could go undetected or not detected and corrected in a timely manner. Repeat Finding: No Recommendation: We recommend that the County retain documentation of review and approval of all expenditures. Views of responsible officials: There is no disagreement with the audit finding.