Audit 372450

2024-005 Procurement, Suspension and Debarment Federal Assistance Listing Numbers – 21.027 Federal Agency – Department of Treasury Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period – 03/31/2021 through 12/31/2024, 10/01/2020 through 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Compliance Requirement: Procurement, Suspension and Debarment Condition: The County did not follow its procurement policy. Additionally, the procurement policy in place does not meet UG requirements, which includes having a policy on suspension and debarment verification. Criteria: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The nonfederal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Unknown Context: During testing, it was noted that the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Furthermore, the County did not retain supporting documentation for the procurement method selected. All six of the transactions tested did not follow the required procedures in place. Cause: The County has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Effect: The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: This is a repeat finding of 2023-004. Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Views of Responsible Officials: There is no disagreement with the finding. The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants.

2024-006 Review of Claim Forms and Expenditure Reconciliations Federal Assistance Listing Numbers – 93.778 Federal Agency –Department of Health and Human Services Federal Program Title – Medicaid Cluster State ID Numbers – Various State Program Title - Various Award Period – 01/01/2024-12/31/2024 Type of Finding: Material Weakness in Internal Control Over Compliance Compliance Requirement: Reporting, Cash Management Condition: The County did not perform review procedures over claims prior to submission or over monthly expenditure reconciliations. Criteria: Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. Review of claims and expenditure reconciliations is an important control over compliance to ensure reports are properly prepared and agree with the County’s actual activity. Questioned Costs: None Context: During reporting testing, it was noted that the County does not have review process in place for reporting or cash management. Cause: There was no review over the monthly claims and monthly expenditures reconciliations prior to submission. Effect: Unallowed costs could be claimed, or costs could be double claimed. Repeat Finding: This is a repeat finding of 2023-005. Recommendation: We recommend that there is an appropriate reviewer of each claim and expenditure reconciliation. Views of Responsible Officials: There is no disagreement with the finding. The County is working to implement review and approval procedures after experiencing significant turnover and transition.