Audit 369653

Department of the U.S. Treasury AL #21.027 – Coronavirus State and Local Fiscal Recovery Funds Grant Period Year Ended June 30, 2024 Criteria: The Compliance and Reporting Guidance for State and Local Fiscal Recovery Funds issued by the U.S. Treasury requires the County to complete an annual Project and Expenditure Report to be filed by April 30. Internal controls should be in place to ensure that this reporting requirement is completed accurately and should include a review of each report completed by an individual knowledgeable in the requirements of the award who did not prepare the report. Such review should occur prior to report submission and should be documented. Condition and Context: The County has contracted with a third-party grant administrator to prepare the annual Project and Expenditure Report, however it currently has no controls in place for a knowledgeable individual within County management to review the report prior to its submission. The County’s Project and Expenditure Report for the reporting period ended March 31, 2024 included cumulative expenditures of $6,414,956 and current period expenditures of $970,822 under one project in the Revenue Replacement category and Provision of Government Services subcategory. The project description references supplementing County infrastructure and other entities due to reduced revenue and increased volume during the pandemic along with additional information related to providing food assistance to low or moderate income households. None of the current period expenditures were related to the provision of food assistance, therefore, it appears that more clear and appropriate categorization and description of projects should be reported. Cause: Presently, the County lacks written procedures to ensure that reporting services provided by its third-party grant administrator are completed accurately in accordance with the U.S. Treasury’s reporting requirements. Effect or Potential Effect: The lack of procedures may result in inaccurate or unclear reporting in relation to the reporting requirements. Questioned Costs: None Repeat Finding: The finding is a repeat finding of 2023-002. Recommendation: We recommend Lincoln County, Nebraska develop written procedures requiring the review of the Project and Expenditure Report prior to its submission. This review should be performed by an individual within County management who is knowledgeable regarding the U.S. Treasury reporting requirements. View of Responsible Officials: Management and governance agree with the finding. See attached Corrective Action Plan.

Department of the U.S. Treasury AL #21.027 – Coronavirus State and Local Fiscal Recovery Funds Grant Period Year Ended June 30, 2024 Criteria: Federal regulations require that non-Federal entities verify that an entity is not excluded or disqualified prior to entering into a covered transaction. The County indicated it had developed procedures to verify through SAM.gov that all vendors are not suspended, debarred or excluded from receiving Federal dollars prior to payment of a claim. Condition and Context: During our procedures, we noted that six claims tested out of a population of 19 claims did not include verification through SAM.gov that the vendor was not suspended, debarred or excluded. For these six claims, we performed a verification through SAM.gov and noted none of the vendors were suspended, debarred or excluded. Cause: While the County indicated it had developed procedures to verify vendors were not suspended, debarred or excluded, its procedures lacked appropriate controls to ensure that these procedures had been implemented prior to the payment of a claim. Effect or Potential Effect: The lack of controls may result in noncompliance with Federal regulations by entering into a covered transaction with an entity who is suspended, debarred or excluded from receiving Federal funds. Questioned Costs: None Repeat Finding: The finding is a repeat finding of 2023-003. Recommendation: We recommend the Board of Commissioners of Lincoln County, Nebraska require documentation that a vendor has been verified through SAM.gov prior to the obligation of any federal funds. We further recommend that the County Clerk’s office review all claims submitted against federal funds to ensure the SAM.gov verification is attached to the request for payment. View of Responsible Officials: Management and governance agree with the finding. See attached Corrective Action Plan.