Reporting Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year(s): B-20-UC-17-0001 and 2020/2021 B-20-UW-17-001 and 2021 CDBG ? Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants, Federal Assistance Listing #14.218 County Department ? Department of Planning and Development Finding 2022 ? 001 CRITERIA Per the 2021 Funding approval/agreement with the U.S. Department of Housing and Urban Development (HUD), Section 8 Special Conditions (c) states, ?In addition to the conditions contained on form HUD 7082, the grantee shall comply with requirements established by the Office of Management and Budget (OMB) concerning the Dun and Bradstreet Data Universal Numbering System (DUNS); the System for Award Management (SAM.gov.); the Federal Funding Accountability and Transparency Act as provided in 2 CFR part 25, Universal Identifier and General Contractor Registration; and 2 CFR part 170, Reporting Subaward and Executive Compensation Information.? The Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) website states, ?FSRS is the reporting tool Federal prime awardees (i.e. prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements. Prime contract awardees will report against sub-contracts awarded, and prime grant awardees will report against sub-grants awarded.? In addition, ?Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.? In accordance with 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, Appendix A, Award Term, b. 1. Reporting total compensation of recipient executives for non-Federal entities, states, ?You must report total compensation for each of your five most highly compensated executives for the preceding completed fiscal year, if - i. The total Federal funding authorized to date under this Federal award equals or exceeds $30,000 as defined in 2 CFR 170.320; ii. in the preceding fiscal year, you received? (A) 80 percent or more of your annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards), and (B) $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); and, iii. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. 2. Where and when to report. You must report executive total compensation described in paragraph b.1. of this award term: i. As part of your registration profile at https://www.sam.gov. ii. By the end of the month following the month in which this award is made, and annually thereafter.? SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year(s): B-20-UC-17-0001 and 2020/2021 B-20-UW-17-001 and 2021 CDBG ? Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants, Federal Assistance Listing #14.218 County Department ? Department of Planning and Development Finding 2022 ? 001 (Continued) CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not comply with its FFATA reporting requirements as outlined in its grant agreement and federal regulations. CAUSE Based on discussions with management, this finding occurred due to establishing threshold requirements for subrecipient reporting. DPD collects information annually from sub-recipients receiving CDBG grant funds. Awarded subrecipients are required to submit self-attestation forms to DPD hosted grant workshops. The completed forms determine the subrecipient reporting requirements. In 2022, selected subrecipients did not meet the threshold for reporting salaries of top executives as determined by the federal regulations. EFFECT Failure to prepare and submit required reports is a violation of federal regulations and impairs the grantor agency?s ability to adequately monitor the program activities/federally funded program. QUESTIONED COSTS None. CONTEXT Based on our review of the fiscal year 2022 grant disbursements, we noted a total of 45 subrecipients had expenditures greater than $30,000. We selected 9 subgrantee (subrecipients) for review and noted that DPD did not submit any reporting information as required under the FFATA Subaward Reporting, in the FSRS system. IDENTIFICATION OF REPEATED FINDINGS None. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year(s): B-20-UC-17-0001 and 2020/2021 B-20-UW-17-001 and 2021 CDBG ? Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants, Federal Assistance Listing #14.218 County Department ? Department of Planning and Development Finding 2022 ? 001 (Continued) RECOMMENDATION We recommend that DPD develop and implement procedures to ensure required reports are prepared, reviewed, and submitted in a timely manner and in compliance with its grant agreement and federal regulations. Per federal regulations, prime grant recipients awarded a new federal grant greater than or equal to $30,000 as of October 1, 2010, are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee, County DPD, is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If any federal requirement is unclear, we recommend that DPD reach out to its grantor agency for additional clarification and guidance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 60.
Special Tests and Provisions Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: E-20-UW-17-0001 and 2020 E-20-UC-17-0001 and 2020 Emergency Solutions Grant Program, Federal Assistance Listing #14.231 County Department ? Department of Planning and Development Finding 2022 ? 002 CRITERIA 24 CFR Part 576, Emergency Solutions Grants Program, Subpart C - Award and Use of Funds, Section 576.203 Obligations, expenditure, and payments requirements (c) Payments to Subrecipients states, ?The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. This requirement also applies to each subrecipient that is a unit of general-purpose local government.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with its special tests and provisions requirements in accordance with federal regulations. CAUSE Based on discussions with management, this finding occurred because the ESG program has a complicated billing structure which includes five (5) different spending areas from which a subrecipient can select for payment. This complicated billing structure forces DPD staff to provide an extensive amount of technical assistance to various subrecipients due to incorrect invoice submissions. Many of the subrecipients are understaffed and lack the capacity to bill properly. DPD staff spent a significant amount of time providing technical assistance to subrecipients with the preparation of requests for reimbursements. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request is a violation of federal regulations. This could impact the subrecipient?s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Special Tests and Provisions Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: E-20-UW-17-0001 and 2020 E-20-UC-17-0001 and 2020 Emergency Solutions Grant Program, Federal Assistance Listing #14.231 County Department ? Department of Planning and Development Finding 2022 ? 002 (Continued) CONTEXT During our test of 44 subrecipients? expenditures, we noted four instances where payments to the subrecipients were not made within 30 days after receiving the subrecipient?s complete payment request, as required. The payments were submitted late, ranging from 46 to 140 days late. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients complete payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on pages 60-61.
Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 CRITERIA Per the U.S Department of the Treasury, Emergency Rental Assistance, Frequently Asked Questions, revised July 27, 2022 (FAQ), ?In ERA 1, an eligible household may receive up to twelve (12) months of assistance (plus an additional three (3) months if necessary to ensure housing stability for the household, subject to the availability of funds). The aggregate amount of financial assistance an eligible household may receive under ERA 2, when combined with financial assistance under ERA 1, must not exceed 18 months.? In addition, the FAQ states, ?In ERA1, financial assistance for prospective rent payments is limited to three months based on any application by or on behalf of the household, except that the household may receive assistance for prospective rent payments for additional months (i) subject to the availability of remaining funds currently allocated to the grantee, and (ii) based on a subsequent application for additional assistance. In no case may an eligible household receive more than 18 months of assistance under ERA 1 and ERA 2, combined.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with federal regulations over eligibility requirements. CAUSE Based on discussions with management, this finding occurred due to an oversight in the procedure to check payments for the monthly cap of eighteen months by a reviewer, as the system did not have a calculated field on ?number of months? paid with a built-in cap that was subsequently added to the application system to limit payments to the cap number of months (18) for ERA I, ERA II combined. EFFECT The failure to ensure rental assistance payments are made during the periods allowed under the program is a violation of federal regulations. This could result in ineligible participants being paid/charged to the federally funded program. QUESTIONED COSTS We noted total potential questioned costs in the amount of $12,712. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 (Continued) CONTEXT During our test of 40 participants, we noted a total of 5 participants received ERA 1 and/or ERA 2 rental assistance payments either beyond the maximum period allowed or during ineligible periods. Specifically, we noted the following: *Two participants received ERA 1 payments beyond the 15 months allowed. *One participant received both ERA 1 and ERA 2 payments beyond the 18 months allowed. *One participant was overpaid 3 months of future rental assistance payment. *One participant received rental assistance payment before March 13, 2020, the date of the emergency declaration pursuant to section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5191(b), which were during ineligible periods. These issues resulted in the overpayment of rental assistance during fiscal year 2022 totaling $12,712. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure compliance with federal regulations. Also, procedures should be in place to ensure rental assistance payments does not exceed the maximum period allowed under the program and is within the periods allowed. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 61.
Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 CRITERIA Per the U.S Department of the Treasury, Emergency Rental Assistance, Frequently Asked Questions, revised July 27, 2022 (FAQ), ?In ERA 1, an eligible household may receive up to twelve (12) months of assistance (plus an additional three (3) months if necessary to ensure housing stability for the household, subject to the availability of funds). The aggregate amount of financial assistance an eligible household may receive under ERA 2, when combined with financial assistance under ERA 1, must not exceed 18 months.? In addition, the FAQ states, ?In ERA1, financial assistance for prospective rent payments is limited to three months based on any application by or on behalf of the household, except that the household may receive assistance for prospective rent payments for additional months (i) subject to the availability of remaining funds currently allocated to the grantee, and (ii) based on a subsequent application for additional assistance. In no case may an eligible household receive more than 18 months of assistance under ERA 1 and ERA 2, combined.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with federal regulations over eligibility requirements. CAUSE Based on discussions with management, this finding occurred due to an oversight in the procedure to check payments for the monthly cap of eighteen months by a reviewer, as the system did not have a calculated field on ?number of months? paid with a built-in cap that was subsequently added to the application system to limit payments to the cap number of months (18) for ERA I, ERA II combined. EFFECT The failure to ensure rental assistance payments are made during the periods allowed under the program is a violation of federal regulations. This could result in ineligible participants being paid/charged to the federally funded program. QUESTIONED COSTS We noted total potential questioned costs in the amount of $12,712. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 (Continued) CONTEXT During our test of 40 participants, we noted a total of 5 participants received ERA 1 and/or ERA 2 rental assistance payments either beyond the maximum period allowed or during ineligible periods. Specifically, we noted the following: *Two participants received ERA 1 payments beyond the 15 months allowed. *One participant received both ERA 1 and ERA 2 payments beyond the 18 months allowed. *One participant was overpaid 3 months of future rental assistance payment. *One participant received rental assistance payment before March 13, 2020, the date of the emergency declaration pursuant to section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5191(b), which were during ineligible periods. These issues resulted in the overpayment of rental assistance during fiscal year 2022 totaling $12,712. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure compliance with federal regulations. Also, procedures should be in place to ensure rental assistance payments does not exceed the maximum period allowed under the program and is within the periods allowed. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 61.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from the Program Leads and Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidence the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 38 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 17 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 008 CRITERIA Per the U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (CDC), Notice of Funding Opportunity (NOFO) number CDC-RFA-OT21-2103, entitled, ?National Initiative to Address COVID-19 Health Disparities Among Populations at High-Risk and Underserved, Including Racial and Ethnic Minority Populations and Rural Communities?, dated May 3, 2021, Section 4. Federal Funding Accountability and Transparency Act of 2006 (FFATA), states ?Compliance with this law is primarily the responsibility of the Federal agency. However, two elements of the law require information to be collected and reported by applicants: 1) information on executive compensation when not already reported through the SAM, and 2) similar information on all sub-awards/subcontracts/consortiums over $25,000.? The Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) website states, ?FSRS is the reporting tool Federal prime awardees (i.e. prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements. Prime contract awardees will report against sub-contracts awarded, and prime grant awardees will report against sub-grants awarded.? In addition, ?Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.? In accordance with 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, Appendix A, Award Term, b. 1. Reporting total compensation of recipient executives for non-Federal entities, states, ?You must report total compensation for each of your five most highly compensated executives for the preceding completed fiscal year, if - i. The total Federal funding authorized to date under this Federal award equals or exceeds $30,000 as defined in 2 CFR 170.320; ii. in the preceding fiscal year, you received? (A) 80 percent or more of your annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards), and (B) $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); and, iii. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 008 (Continued) CRITERIA (Continued) 2. Where and when to report. You must report executive total compensation described in paragraph b.1. of this award term: i. As part of your registration profile at https://www.sam.gov. ii. By the end of the month following the month in which this award is made, and annually thereafter.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not comply with its FFATA reporting requirements as outlined in its notice of award and federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from having subrecipients in the grant application identified as vendors. As a result, staff classified the associated costs as professional services instead of grant disbursements which is used to identify subrecipient(s) on the grant. Also, the Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff to prepare and submit the FFATA reporting. EFFECT Failure to prepare and submit required reports is a violation of federal regulations and impairs the grantor agency?s ability to adequately monitor the program activities/federally funded program. QUESTIONED COSTS None. CONTEXT Based on our review of the fiscal year 2022 grant disbursements, we noted a total of 13 subrecipients had expenditures greater than $30,000. We selected 4 subgrantee (subrecipients) for review and noted that DPH did not submit any reporting information as required under the FFATA Subaward Reporting, in the FSRS system. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 008 (Continued) IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPH develop and implement procedures to ensure required reports are prepared, reviewed, and submitted in a timely manner and in compliance with its grant agreement and federal regulations. Also, sub-grant agreements and related expenditures incurred should be reviewed to ensure the appropriate determination, classification, and reporting of subrecipients. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 64.
Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D?Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from subrecipients being identified as vendors in the grant application. Also, the Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. EFFECT Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH?s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the current audit period, we noted 27 subrecipients were awarded funds. During our review of 6 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support DPH?s evaluation of each subrecipients risk of noncompliance and the frequency of monitoring to be conducted by DPH based on the assessed risk. Also, we noted no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including DPH?s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONTEXT (Continued) In addition, while we noted that DPH does have a draft policy manual regarding the monitoring of its subrecipients, we noted the manual does not currently address or include the process and related procedures for conducting both fiscal and programmatic monitoring. Specifically, the draft manual does not: a) include any related checklists and/or forms being utilized, b) address the performance of risk assessments, or c) detail the frequency and type of monitoring (i.e., desk review, site visit) to be conducted based on assessed risks. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332 and once updated the draft policy should be finalized and implemented. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 64.
Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 CRITERIA Per the U.S. Department of Health and Human Services, Health Resources and Service Administration (HRSA) User Guide on Provider Relief Fund (PRF) Reporting Portal - Reporting dated June 30, 2021 (User Guide), Post-Payment Reporting Requirements, Section 1.3, ?PRF recipients should review the most recently published Post-Payment Notice of Reporting Requirements available on the PRF Reporting Requirements & Auditing website for information about reporting requirements?. Per the June 11, 2021, Post-Payment Notice of Reporting Requirements, Provider Relief Fund General and Targeted Distribution (which superseded the notice released on January 15, 2021), ?The period of availability of funds applies to all past and future PRF payments made under the legal authorities outlined in the section Overview of Legal Requirements for Reporting. PRF recipients must only use payments for eligible expenses, including services rendered, and lost revenue during the period of availability.? In addition, the June 11 Notice of Reporting Requirements states ?Reporting Entities will report on their use of funds using their normal basis of accounting (e.g., cash basis, accrual basis). Recipients will report data in the following order: 1) Interest Earned on PRF Payment(s); 2 Other Assistance Received; 3) Use of SNF and Nursing Home Infection Control Distribution Payments (if applicable); 4) Use of General and Other Targeted Distribution Payments; 5) Net Unreimbursed Expenses Attributable to Coronavirus; 6) Lost Revenues Reimbursement and various other data elements, as required.? Step 9 of the User Guide ? Other Provider Relief Funds Expenses for Payments Received During Payment Period states the Reporting Entity is required to report on the use of all other PRF payments by indicating the calendar year quarterly expenses reimbursed with these payments. PRF payments must be used for expenses unreimbursed by other sources and that other sources are not obligated to reimburse. Reporting Entities that received $500,000 or more in aggregated PRF payments during each Payment Received Period are required to report on the use of these other PRF payments in greater detail than the two categories of General and Administrative (G&A) Expenses and Health Care-Related Expenses, according to the following sub-categories of expenses: 1) General and Administrative Expenses Attributable to Coronavirus: a) Mortgage/Rent; b) Insurance; c) Personnel; d) Fringe Benefits; e) Lease Payments; f) Utilities/Operations; g) Other General and Administrative Expenses. 2) Health Care-Related Expenses Attributable to Coronavirus: a) Supplies; b) Equipment; c) Information Technology; d) Facilities: e) Other Health Care-Related Expenses." Step 10 of the User Guide ? Unreimbursed Expenses Attributable to Coronavirus states HRSA expects that PRF payments would be applied to unreimbursed expenses attributable to the coronavirus that are not obligated to be reimbursed by other sources before Provider Relief Fund payments are used for lost revenue. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 (Continued) CRITERIA (Continued) Per the Provider Relief Fund and ARP Rural Payments, Frequently Asked Questions (FAQ) (last updated 2/25/2022), Use of Funds Section (modified 8/30/2021), ?To be considered an allowable expense under the PRF, the expense must be used to prevent, prepare for, and respond to the coronavirus. Reporting Entities are required to maintain adequate documentation to substantiate that these funds were used for health care-related expenses or lost revenue attributable to the coronavirus, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them. Reporting Entities are not required to submit that documentation when reporting. Providers are required to maintain supporting documentation that demonstrates costs were incurred during the period of availability. The Reporting Entity is responsible for ensuring that adequate documentation is maintained.? 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, Section 200.303 states, ?the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? CONDITION During the current audit period, Cook County Health (CCH) did not accurately prepare its Period 2 report submitted via the HRSA Reporting portal in accordance with the federal reporting requirements. CAUSE Based on discussions with management, the cause of this finding resulted from a misunderstanding of the expense data that was rolling/ inputted in the HRSA portal. The unreimbursed expenses line should have been inputted as Other PRF Expenses. CCH Management has already instituted a Corrective Action Plan (CAP) to prevent future occurrence. EFFECT Failure to ensure the Period 2 report is accurately prepared could impair the grantor agency?s ability to adequately monitor the federally funded program. Also, this failure resulted in inaccurate reporting of other PRF expenses and loss revenue during Period 2 Reporting, which will impact the subsequent and future PRF Period reports under the program. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 (Continued) QUESTIONED COSTS None. CONTEXT During the prior audit period, we noted that Period 1 report submitted to HRSA was prepared in error, which resulted in a 2021 audit finding and subsequent corrective action planned prepared by CCH to address the finding. During the current audit period, we noted CCH did not have adequate time to implement its corrective action plan. As a result, the Period 2 report (which included $31,163,323 as payments received during the period from July 1, 2020 to December 31, 2020) submitted to HRSA was also prepared in error. Specifically, we noted the following: *The $31,163,323 categorized as other PRF expenses included amounts reimbursed by FEMA program(s), hence reimbursed from other (federal) sources. Hence, this amount was reported in error, which is a violation of the HRSA reporting requirements. *The other assistance received section of the report does not appear to include all other federal assistance received by CCH during the year. *CCH used the same methodologies included in the Period 1 Report to calculate its incremental costs attributable to the coronavirus. CCH (based on their understanding of the HRSA Provider Relief document modified 12/14/2020, which permitted reimbursement of marginal increased expenses related to the coronavirus) determined its net unreimbursed/incremental expenses incurred by calculating the increase in cost per (patient) discharge during the period of availability. These incremental costs per discharge were then applied to the discharge adjusted factor indicator (calculated by CCH as admits or discharges (excluding newborns) multiplied by (total charges/in-patient charges)) during the same period. This methodology resulted in total estimated incremental costs during Period 2 reporting of $72,889,648 which (after excluding expenses reimbursed from other sources reported of $29,966,420) resulted in net unreimbursed expenses attributable to coronavirus of $42,923,228 during the period of availability. However, we noted the current HRSA guidance, (FAQ, modified 2/25/2022, which was applicable during Period 2 reporting) no longer included language which permitted the reimbursement of such marginal increased expenses related to the coronavirus. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 (Continued) CONTEXT (Continued) Overall, it was noted that CCH had unreimbursed (unused) loss revenues available to be applied to the reporting period of $38,654,147, which exceeded the $31.6M payments received. This unused loss revenue could have been applied if the report had been accurately prepared. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2021-003) RECOMMENDATION We recommend that CCH implements its prior corrective action plan for any future reports to be prepared and submitted under the PRF program. Also, procedures should be implemented to ensure accurate preparation of its report(s) in accordance with HRSA reporting requirements and to ensure the report(s) are properly reviewed by a second individual prior to submission. In addition, we suggest that CCH maintains an internal schedule to accurately track its related PRF expenses and loss revenue during each applicable reporting period, especially in instances where the prior period(s) reports were inaccurately prepared. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on pages 65-66.
Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: 6NU5OCK000559-01-08 and 2020 Pass-through Illinois Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Department of Public Health Finding 2022 ? 005 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with federal regulations over allowable costs. CAUSE Based on discussions with management, the cause of this finding resulted from not following the established controls that ensure proper support documentation is included with the journal entry chargeback entries prepared by Finance staff to justify the charges incurred to the Grant. Additionally, the Program Lead (key personnel) assigned to the program left the organization prior to the Grant ending which affected the periodic review for allowable costs/charges. EFFECT The failure to maintain adequate supporting documentation and to ensure all expenditures are allowable, reasonable, and properly reviewed and approved resulted in the identification of questioned costs and is a violation of federal regulations. QUESTIONED COSTS We noted total potential questioned costs in the amount of $336,583. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: 6NU5OCK000559-01-08 and 2020 Pass-through Illinois Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Department of Public Health Finding 2022 ? 005 (Continued) CONTEXT During fiscal year 2022, we noted total program expenditures were incurred under five grant agreements (three with the Illinois Department of Public Health (IDPH) and two with the City of Chicago). For the IDPH grants, we tested 6 expenditure samples (from a population of 28), noting for two expenditures (totaling $1,618,957), adequate documentation was not initially provided to support the total amount charged to the program. As a result, DPH management subsequently provided a reconciliation of additional grant expenditures to support these charges. Upon further review, we noted that only $1,282,374 represents allowable costs that could be charged to the program, as other amounts noted were previously transferred to the grant in prior periods. The unreconciled difference of $336,583 remains unsupported and as such, represented potential questioned costs under the IDPH funded portion of the program. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH ensure adequate documentation is maintained to support charges to the federal program and comply with federal regulations. Also, procedures should be developed and implemented to ensure all expenditures are allowable, reasonable, and properly reviewed and approved prior to charging the expenditures to the federally funded program. Finally, periodic and timely reconciliation of grant activities should be performed to ensure only allowable costs are being reported under the program. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NU50CK000556 and 2020 Pass-through City of Chicago, Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Cook County Health Finding 2022 ? 006 CRITERIA As required by the grant agreement with the City of Chicago, the grantee must submit detailed monthly requisitions for reimbursement identifying the payment due for the services performed and/or costs incurred and paid directly by grantee. The requisitions must be submitted within 15 calendar days after the end of the month in which the grantee performed services and/or incurred and paid costs. CONDITION During the current audit period, Cook County Health (CCH) did not comply with the reporting requirements as outlined in its grant agreement. CAUSE Based on discussions with management, this finding occurred due to the grant agreement received from the City of Chicago was executed late and insufficient internal controls were in place to ensure the grant was assigned to the Department?s Grant vouchering tracking schedule to determine when the grant monthly voucher reports are due to the City of Chicago. EFFECT Failure to submit reports in a timely manner impairs the grantor agency?s ability to monitor program activities and could result in the loss of grant funding. Also, the failure to ensure expenditures included in the reports submitted to the grantor agency resulted in the under-reporting of grant expenditures on the schedule of expenditures of federal awards. QUESTIONED COSTS None. CONTEXT During our review of four monthly reports submitted under the City of Chicago grants, we noted two reports were submitted late, as noted below: SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NU50CK000556 and 2020 Pass-through City of Chicago, Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Cook County Health Finding 2022 ? 006 (Continued) CONTEXT (Continued) Report Period Due Date Submission Date Days Late 3/1/2022-3/31/2022 4/15/2022 8/30/2022 137 7/1/2022-7/31/2022 8/15/2022 8/30/2022 15 In addition, for the remaining two reports covering the periods from 10/1/2022 to 10/31/2022 and 11/1/2022 to 11/30/2022, we noted expenditures of $7,126 and $7,608 respectively, included on the reports, which were not recorded as federal grant expenditures in the Oracle accounting system. Consequently, this resulted in an adjustment to the schedule of expenditures of federal awards to not only include these amounts, but the total grant expenditures incurred totaling $931,606 under the federal program during 2022. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2021-004) RECOMMENDATION We recommend that CCH develop and implement procedures to ensure reports are submitted in a timely manner and in compliance with its grant agreements. A compliance calendar of all grants reporting due dates should be maintained to assist with ensuring compliance with reporting requirements. In addition, we recommend CCH ensure all expenditures included on grant reports are properly reported in the schedule of expenditures of federal awards. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from Program Leads and the Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by the established County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidencing the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 35 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 12 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 62.
Reporting Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year(s): B-20-UC-17-0001 and 2020/2021 B-20-UW-17-001 and 2021 CDBG ? Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants, Federal Assistance Listing #14.218 County Department ? Department of Planning and Development Finding 2022 ? 001 CRITERIA Per the 2021 Funding approval/agreement with the U.S. Department of Housing and Urban Development (HUD), Section 8 Special Conditions (c) states, ?In addition to the conditions contained on form HUD 7082, the grantee shall comply with requirements established by the Office of Management and Budget (OMB) concerning the Dun and Bradstreet Data Universal Numbering System (DUNS); the System for Award Management (SAM.gov.); the Federal Funding Accountability and Transparency Act as provided in 2 CFR part 25, Universal Identifier and General Contractor Registration; and 2 CFR part 170, Reporting Subaward and Executive Compensation Information.? The Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) website states, ?FSRS is the reporting tool Federal prime awardees (i.e. prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements. Prime contract awardees will report against sub-contracts awarded, and prime grant awardees will report against sub-grants awarded.? In addition, ?Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.? In accordance with 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, Appendix A, Award Term, b. 1. Reporting total compensation of recipient executives for non-Federal entities, states, ?You must report total compensation for each of your five most highly compensated executives for the preceding completed fiscal year, if - i. The total Federal funding authorized to date under this Federal award equals or exceeds $30,000 as defined in 2 CFR 170.320; ii. in the preceding fiscal year, you received? (A) 80 percent or more of your annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards), and (B) $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); and, iii. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. 2. Where and when to report. You must report executive total compensation described in paragraph b.1. of this award term: i. As part of your registration profile at https://www.sam.gov. ii. By the end of the month following the month in which this award is made, and annually thereafter.? SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year(s): B-20-UC-17-0001 and 2020/2021 B-20-UW-17-001 and 2021 CDBG ? Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants, Federal Assistance Listing #14.218 County Department ? Department of Planning and Development Finding 2022 ? 001 (Continued) CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not comply with its FFATA reporting requirements as outlined in its grant agreement and federal regulations. CAUSE Based on discussions with management, this finding occurred due to establishing threshold requirements for subrecipient reporting. DPD collects information annually from sub-recipients receiving CDBG grant funds. Awarded subrecipients are required to submit self-attestation forms to DPD hosted grant workshops. The completed forms determine the subrecipient reporting requirements. In 2022, selected subrecipients did not meet the threshold for reporting salaries of top executives as determined by the federal regulations. EFFECT Failure to prepare and submit required reports is a violation of federal regulations and impairs the grantor agency?s ability to adequately monitor the program activities/federally funded program. QUESTIONED COSTS None. CONTEXT Based on our review of the fiscal year 2022 grant disbursements, we noted a total of 45 subrecipients had expenditures greater than $30,000. We selected 9 subgrantee (subrecipients) for review and noted that DPD did not submit any reporting information as required under the FFATA Subaward Reporting, in the FSRS system. IDENTIFICATION OF REPEATED FINDINGS None. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year(s): B-20-UC-17-0001 and 2020/2021 B-20-UW-17-001 and 2021 CDBG ? Entitlement Grants Cluster: Community Development Block Grants/Entitlement Grants, Federal Assistance Listing #14.218 County Department ? Department of Planning and Development Finding 2022 ? 001 (Continued) RECOMMENDATION We recommend that DPD develop and implement procedures to ensure required reports are prepared, reviewed, and submitted in a timely manner and in compliance with its grant agreement and federal regulations. Per federal regulations, prime grant recipients awarded a new federal grant greater than or equal to $30,000 as of October 1, 2010, are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee, County DPD, is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. If any federal requirement is unclear, we recommend that DPD reach out to its grantor agency for additional clarification and guidance. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 60.
Special Tests and Provisions Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: E-20-UW-17-0001 and 2020 E-20-UC-17-0001 and 2020 Emergency Solutions Grant Program, Federal Assistance Listing #14.231 County Department ? Department of Planning and Development Finding 2022 ? 002 CRITERIA 24 CFR Part 576, Emergency Solutions Grants Program, Subpart C - Award and Use of Funds, Section 576.203 Obligations, expenditure, and payments requirements (c) Payments to Subrecipients states, ?The recipient must pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request. This requirement also applies to each subrecipient that is a unit of general-purpose local government.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with its special tests and provisions requirements in accordance with federal regulations. CAUSE Based on discussions with management, this finding occurred because the ESG program has a complicated billing structure which includes five (5) different spending areas from which a subrecipient can select for payment. This complicated billing structure forces DPD staff to provide an extensive amount of technical assistance to various subrecipients due to incorrect invoice submissions. Many of the subrecipients are understaffed and lack the capacity to bill properly. DPD staff spent a significant amount of time providing technical assistance to subrecipients with the preparation of requests for reimbursements. EFFECT The failure to pay each subrecipient for allowable costs within 30 days after receiving the subrecipient?s complete payment request is a violation of federal regulations. This could impact the subrecipient?s ability to adequately perform its programmatic responsibilities under the program. QUESTIONED COSTS None. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Special Tests and Provisions Federal Department ? U.S. Department of Housing and Urban Development Federal Award Identification Number and Year: E-20-UW-17-0001 and 2020 E-20-UC-17-0001 and 2020 Emergency Solutions Grant Program, Federal Assistance Listing #14.231 County Department ? Department of Planning and Development Finding 2022 ? 002 (Continued) CONTEXT During our test of 44 subrecipients? expenditures, we noted four instances where payments to the subrecipients were not made within 30 days after receiving the subrecipient?s complete payment request, as required. The payments were submitted late, ranging from 46 to 140 days late. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure payments to subrecipients are made within 30 days after receipt of the subrecipients complete payment request, as required. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on pages 60-61.
Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 CRITERIA Per the U.S Department of the Treasury, Emergency Rental Assistance, Frequently Asked Questions, revised July 27, 2022 (FAQ), ?In ERA 1, an eligible household may receive up to twelve (12) months of assistance (plus an additional three (3) months if necessary to ensure housing stability for the household, subject to the availability of funds). The aggregate amount of financial assistance an eligible household may receive under ERA 2, when combined with financial assistance under ERA 1, must not exceed 18 months.? In addition, the FAQ states, ?In ERA1, financial assistance for prospective rent payments is limited to three months based on any application by or on behalf of the household, except that the household may receive assistance for prospective rent payments for additional months (i) subject to the availability of remaining funds currently allocated to the grantee, and (ii) based on a subsequent application for additional assistance. In no case may an eligible household receive more than 18 months of assistance under ERA 1 and ERA 2, combined.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with federal regulations over eligibility requirements. CAUSE Based on discussions with management, this finding occurred due to an oversight in the procedure to check payments for the monthly cap of eighteen months by a reviewer, as the system did not have a calculated field on ?number of months? paid with a built-in cap that was subsequently added to the application system to limit payments to the cap number of months (18) for ERA I, ERA II combined. EFFECT The failure to ensure rental assistance payments are made during the periods allowed under the program is a violation of federal regulations. This could result in ineligible participants being paid/charged to the federally funded program. QUESTIONED COSTS We noted total potential questioned costs in the amount of $12,712. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 (Continued) CONTEXT During our test of 40 participants, we noted a total of 5 participants received ERA 1 and/or ERA 2 rental assistance payments either beyond the maximum period allowed or during ineligible periods. Specifically, we noted the following: *Two participants received ERA 1 payments beyond the 15 months allowed. *One participant received both ERA 1 and ERA 2 payments beyond the 18 months allowed. *One participant was overpaid 3 months of future rental assistance payment. *One participant received rental assistance payment before March 13, 2020, the date of the emergency declaration pursuant to section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5191(b), which were during ineligible periods. These issues resulted in the overpayment of rental assistance during fiscal year 2022 totaling $12,712. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure compliance with federal regulations. Also, procedures should be in place to ensure rental assistance payments does not exceed the maximum period allowed under the program and is within the periods allowed. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 61.
Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 CRITERIA Per the U.S Department of the Treasury, Emergency Rental Assistance, Frequently Asked Questions, revised July 27, 2022 (FAQ), ?In ERA 1, an eligible household may receive up to twelve (12) months of assistance (plus an additional three (3) months if necessary to ensure housing stability for the household, subject to the availability of funds). The aggregate amount of financial assistance an eligible household may receive under ERA 2, when combined with financial assistance under ERA 1, must not exceed 18 months.? In addition, the FAQ states, ?In ERA1, financial assistance for prospective rent payments is limited to three months based on any application by or on behalf of the household, except that the household may receive assistance for prospective rent payments for additional months (i) subject to the availability of remaining funds currently allocated to the grantee, and (ii) based on a subsequent application for additional assistance. In no case may an eligible household receive more than 18 months of assistance under ERA 1 and ERA 2, combined.? CONDITION During the current audit period, the Cook County Department of Planning and Development (DPD) did not adequately comply with federal regulations over eligibility requirements. CAUSE Based on discussions with management, this finding occurred due to an oversight in the procedure to check payments for the monthly cap of eighteen months by a reviewer, as the system did not have a calculated field on ?number of months? paid with a built-in cap that was subsequently added to the application system to limit payments to the cap number of months (18) for ERA I, ERA II combined. EFFECT The failure to ensure rental assistance payments are made during the periods allowed under the program is a violation of federal regulations. This could result in ineligible participants being paid/charged to the federally funded program. QUESTIONED COSTS We noted total potential questioned costs in the amount of $12,712. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Eligibility Federal Department ? U.S. Department of Treasury Pass-through the Illinois Department of Human Services COVID-19- Emergency Rental Assistance Program, Federal Assistance Listing #21.023 County Department ? Department of Planning and Development Finding 2022 ? 003 (Continued) CONTEXT During our test of 40 participants, we noted a total of 5 participants received ERA 1 and/or ERA 2 rental assistance payments either beyond the maximum period allowed or during ineligible periods. Specifically, we noted the following: *Two participants received ERA 1 payments beyond the 15 months allowed. *One participant received both ERA 1 and ERA 2 payments beyond the 18 months allowed. *One participant was overpaid 3 months of future rental assistance payment. *One participant received rental assistance payment before March 13, 2020, the date of the emergency declaration pursuant to section 501(b) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5191(b), which were during ineligible periods. These issues resulted in the overpayment of rental assistance during fiscal year 2022 totaling $12,712. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPD develop and implement procedures to ensure compliance with federal regulations. Also, procedures should be in place to ensure rental assistance payments does not exceed the maximum period allowed under the program and is within the periods allowed. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 61.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from the Program Leads and Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 007 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidence the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 38 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 17 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 008 CRITERIA Per the U.S. Department of Health and Human Services, Centers for Disease Control and Prevention (CDC), Notice of Funding Opportunity (NOFO) number CDC-RFA-OT21-2103, entitled, ?National Initiative to Address COVID-19 Health Disparities Among Populations at High-Risk and Underserved, Including Racial and Ethnic Minority Populations and Rural Communities?, dated May 3, 2021, Section 4. Federal Funding Accountability and Transparency Act of 2006 (FFATA), states ?Compliance with this law is primarily the responsibility of the Federal agency. However, two elements of the law require information to be collected and reported by applicants: 1) information on executive compensation when not already reported through the SAM, and 2) similar information on all sub-awards/subcontracts/consortiums over $25,000.? The Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) website states, ?FSRS is the reporting tool Federal prime awardees (i.e. prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements. Prime contract awardees will report against sub-contracts awarded, and prime grant awardees will report against sub-grants awarded.? In addition, ?Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.? In accordance with 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, Appendix A, Award Term, b. 1. Reporting total compensation of recipient executives for non-Federal entities, states, ?You must report total compensation for each of your five most highly compensated executives for the preceding completed fiscal year, if - i. The total Federal funding authorized to date under this Federal award equals or exceeds $30,000 as defined in 2 CFR 170.320; ii. in the preceding fiscal year, you received? (A) 80 percent or more of your annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards), and (B) $25,000,000 or more in annual gross revenues from Federal procurement contracts (and subcontracts) and Federal financial assistance subject to the Transparency Act, as defined at 2 CFR 170.320 (and subawards); and, iii. The public does not have access to information about the compensation of the executives through periodic reports filed under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 008 (Continued) CRITERIA (Continued) 2. Where and when to report. You must report executive total compensation described in paragraph b.1. of this award term: i. As part of your registration profile at https://www.sam.gov. ii. By the end of the month following the month in which this award is made, and annually thereafter.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not comply with its FFATA reporting requirements as outlined in its notice of award and federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from having subrecipients in the grant application identified as vendors. As a result, staff classified the associated costs as professional services instead of grant disbursements which is used to identify subrecipient(s) on the grant. Also, the Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff to prepare and submit the FFATA reporting. EFFECT Failure to prepare and submit required reports is a violation of federal regulations and impairs the grantor agency?s ability to adequately monitor the program activities/federally funded program. QUESTIONED COSTS None. CONTEXT Based on our review of the fiscal year 2022 grant disbursements, we noted a total of 13 subrecipients had expenditures greater than $30,000. We selected 4 subgrantee (subrecipients) for review and noted that DPH did not submit any reporting information as required under the FFATA Subaward Reporting, in the FSRS system. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 008 (Continued) IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend that DPH develop and implement procedures to ensure required reports are prepared, reviewed, and submitted in a timely manner and in compliance with its grant agreement and federal regulations. Also, sub-grant agreements and related expenditures incurred should be reviewed to ensure the appropriate determination, classification, and reporting of subrecipients. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 64.
Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D?Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from subrecipients being identified as vendors in the grant application. Also, the Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. EFFECT Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH?s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the current audit period, we noted 27 subrecipients were awarded funds. During our review of 6 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support DPH?s evaluation of each subrecipients risk of noncompliance and the frequency of monitoring to be conducted by DPH based on the assessed risk. Also, we noted no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including DPH?s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONTEXT (Continued) In addition, while we noted that DPH does have a draft policy manual regarding the monitoring of its subrecipients, we noted the manual does not currently address or include the process and related procedures for conducting both fiscal and programmatic monitoring. Specifically, the draft manual does not: a) include any related checklists and/or forms being utilized, b) address the performance of risk assessments, or c) detail the frequency and type of monitoring (i.e., desk review, site visit) to be conducted based on assessed risks. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332 and once updated the draft policy should be finalized and implemented. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 64.
Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 CRITERIA Per the U.S. Department of Health and Human Services, Health Resources and Service Administration (HRSA) User Guide on Provider Relief Fund (PRF) Reporting Portal - Reporting dated June 30, 2021 (User Guide), Post-Payment Reporting Requirements, Section 1.3, ?PRF recipients should review the most recently published Post-Payment Notice of Reporting Requirements available on the PRF Reporting Requirements & Auditing website for information about reporting requirements?. Per the June 11, 2021, Post-Payment Notice of Reporting Requirements, Provider Relief Fund General and Targeted Distribution (which superseded the notice released on January 15, 2021), ?The period of availability of funds applies to all past and future PRF payments made under the legal authorities outlined in the section Overview of Legal Requirements for Reporting. PRF recipients must only use payments for eligible expenses, including services rendered, and lost revenue during the period of availability.? In addition, the June 11 Notice of Reporting Requirements states ?Reporting Entities will report on their use of funds using their normal basis of accounting (e.g., cash basis, accrual basis). Recipients will report data in the following order: 1) Interest Earned on PRF Payment(s); 2 Other Assistance Received; 3) Use of SNF and Nursing Home Infection Control Distribution Payments (if applicable); 4) Use of General and Other Targeted Distribution Payments; 5) Net Unreimbursed Expenses Attributable to Coronavirus; 6) Lost Revenues Reimbursement and various other data elements, as required.? Step 9 of the User Guide ? Other Provider Relief Funds Expenses for Payments Received During Payment Period states the Reporting Entity is required to report on the use of all other PRF payments by indicating the calendar year quarterly expenses reimbursed with these payments. PRF payments must be used for expenses unreimbursed by other sources and that other sources are not obligated to reimburse. Reporting Entities that received $500,000 or more in aggregated PRF payments during each Payment Received Period are required to report on the use of these other PRF payments in greater detail than the two categories of General and Administrative (G&A) Expenses and Health Care-Related Expenses, according to the following sub-categories of expenses: 1) General and Administrative Expenses Attributable to Coronavirus: a) Mortgage/Rent; b) Insurance; c) Personnel; d) Fringe Benefits; e) Lease Payments; f) Utilities/Operations; g) Other General and Administrative Expenses. 2) Health Care-Related Expenses Attributable to Coronavirus: a) Supplies; b) Equipment; c) Information Technology; d) Facilities: e) Other Health Care-Related Expenses." Step 10 of the User Guide ? Unreimbursed Expenses Attributable to Coronavirus states HRSA expects that PRF payments would be applied to unreimbursed expenses attributable to the coronavirus that are not obligated to be reimbursed by other sources before Provider Relief Fund payments are used for lost revenue. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 (Continued) CRITERIA (Continued) Per the Provider Relief Fund and ARP Rural Payments, Frequently Asked Questions (FAQ) (last updated 2/25/2022), Use of Funds Section (modified 8/30/2021), ?To be considered an allowable expense under the PRF, the expense must be used to prevent, prepare for, and respond to the coronavirus. Reporting Entities are required to maintain adequate documentation to substantiate that these funds were used for health care-related expenses or lost revenue attributable to the coronavirus, and that those expenses or losses were not reimbursed from other sources and other sources were not obligated to reimburse them. Reporting Entities are not required to submit that documentation when reporting. Providers are required to maintain supporting documentation that demonstrates costs were incurred during the period of availability. The Reporting Entity is responsible for ensuring that adequate documentation is maintained.? 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D ? Post Federal Award Requirements, Section 200.303 states, ?the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.? CONDITION During the current audit period, Cook County Health (CCH) did not accurately prepare its Period 2 report submitted via the HRSA Reporting portal in accordance with the federal reporting requirements. CAUSE Based on discussions with management, the cause of this finding resulted from a misunderstanding of the expense data that was rolling/ inputted in the HRSA portal. The unreimbursed expenses line should have been inputted as Other PRF Expenses. CCH Management has already instituted a Corrective Action Plan (CAP) to prevent future occurrence. EFFECT Failure to ensure the Period 2 report is accurately prepared could impair the grantor agency?s ability to adequately monitor the federally funded program. Also, this failure resulted in inaccurate reporting of other PRF expenses and loss revenue during Period 2 Reporting, which will impact the subsequent and future PRF Period reports under the program. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 (Continued) QUESTIONED COSTS None. CONTEXT During the prior audit period, we noted that Period 1 report submitted to HRSA was prepared in error, which resulted in a 2021 audit finding and subsequent corrective action planned prepared by CCH to address the finding. During the current audit period, we noted CCH did not have adequate time to implement its corrective action plan. As a result, the Period 2 report (which included $31,163,323 as payments received during the period from July 1, 2020 to December 31, 2020) submitted to HRSA was also prepared in error. Specifically, we noted the following: *The $31,163,323 categorized as other PRF expenses included amounts reimbursed by FEMA program(s), hence reimbursed from other (federal) sources. Hence, this amount was reported in error, which is a violation of the HRSA reporting requirements. *The other assistance received section of the report does not appear to include all other federal assistance received by CCH during the year. *CCH used the same methodologies included in the Period 1 Report to calculate its incremental costs attributable to the coronavirus. CCH (based on their understanding of the HRSA Provider Relief document modified 12/14/2020, which permitted reimbursement of marginal increased expenses related to the coronavirus) determined its net unreimbursed/incremental expenses incurred by calculating the increase in cost per (patient) discharge during the period of availability. These incremental costs per discharge were then applied to the discharge adjusted factor indicator (calculated by CCH as admits or discharges (excluding newborns) multiplied by (total charges/in-patient charges)) during the same period. This methodology resulted in total estimated incremental costs during Period 2 reporting of $72,889,648 which (after excluding expenses reimbursed from other sources reported of $29,966,420) resulted in net unreimbursed expenses attributable to coronavirus of $42,923,228 during the period of availability. However, we noted the current HRSA guidance, (FAQ, modified 2/25/2022, which was applicable during Period 2 reporting) no longer included language which permitted the reimbursement of such marginal increased expenses related to the coronavirus. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services COVID-19 - Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, Federal Assistance Listing # 93.498 County Department ? Cook County Health Finding 2022 ? 010 (Continued) CONTEXT (Continued) Overall, it was noted that CCH had unreimbursed (unused) loss revenues available to be applied to the reporting period of $38,654,147, which exceeded the $31.6M payments received. This unused loss revenue could have been applied if the report had been accurately prepared. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2021-003) RECOMMENDATION We recommend that CCH implements its prior corrective action plan for any future reports to be prepared and submitted under the PRF program. Also, procedures should be implemented to ensure accurate preparation of its report(s) in accordance with HRSA reporting requirements and to ensure the report(s) are properly reviewed by a second individual prior to submission. In addition, we suggest that CCH maintains an internal schedule to accurately track its related PRF expenses and loss revenue during each applicable reporting period, especially in instances where the prior period(s) reports were inaccurately prepared. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on pages 65-66.
Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: 6NU5OCK000559-01-08 and 2020 Pass-through Illinois Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Department of Public Health Finding 2022 ? 005 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not adequately comply with federal regulations over allowable costs. CAUSE Based on discussions with management, the cause of this finding resulted from not following the established controls that ensure proper support documentation is included with the journal entry chargeback entries prepared by Finance staff to justify the charges incurred to the Grant. Additionally, the Program Lead (key personnel) assigned to the program left the organization prior to the Grant ending which affected the periodic review for allowable costs/charges. EFFECT The failure to maintain adequate supporting documentation and to ensure all expenditures are allowable, reasonable, and properly reviewed and approved resulted in the identification of questioned costs and is a violation of federal regulations. QUESTIONED COSTS We noted total potential questioned costs in the amount of $336,583. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: 6NU5OCK000559-01-08 and 2020 Pass-through Illinois Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Department of Public Health Finding 2022 ? 005 (Continued) CONTEXT During fiscal year 2022, we noted total program expenditures were incurred under five grant agreements (three with the Illinois Department of Public Health (IDPH) and two with the City of Chicago). For the IDPH grants, we tested 6 expenditure samples (from a population of 28), noting for two expenditures (totaling $1,618,957), adequate documentation was not initially provided to support the total amount charged to the program. As a result, DPH management subsequently provided a reconciliation of additional grant expenditures to support these charges. Upon further review, we noted that only $1,282,374 represents allowable costs that could be charged to the program, as other amounts noted were previously transferred to the grant in prior periods. The unreconciled difference of $336,583 remains unsupported and as such, represented potential questioned costs under the IDPH funded portion of the program. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH ensure adequate documentation is maintained to support charges to the federal program and comply with federal regulations. Also, procedures should be developed and implemented to ensure all expenditures are allowable, reasonable, and properly reviewed and approved prior to charging the expenditures to the federally funded program. Finally, periodic and timely reconciliation of grant activities should be performed to ensure only allowable costs are being reported under the program. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NU50CK000556 and 2020 Pass-through City of Chicago, Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Cook County Health Finding 2022 ? 006 CRITERIA As required by the grant agreement with the City of Chicago, the grantee must submit detailed monthly requisitions for reimbursement identifying the payment due for the services performed and/or costs incurred and paid directly by grantee. The requisitions must be submitted within 15 calendar days after the end of the month in which the grantee performed services and/or incurred and paid costs. CONDITION During the current audit period, Cook County Health (CCH) did not comply with the reporting requirements as outlined in its grant agreement. CAUSE Based on discussions with management, this finding occurred due to the grant agreement received from the City of Chicago was executed late and insufficient internal controls were in place to ensure the grant was assigned to the Department?s Grant vouchering tracking schedule to determine when the grant monthly voucher reports are due to the City of Chicago. EFFECT Failure to submit reports in a timely manner impairs the grantor agency?s ability to monitor program activities and could result in the loss of grant funding. Also, the failure to ensure expenditures included in the reports submitted to the grantor agency resulted in the under-reporting of grant expenditures on the schedule of expenditures of federal awards. QUESTIONED COSTS None. CONTEXT During our review of four monthly reports submitted under the City of Chicago grants, we noted two reports were submitted late, as noted below: SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Reporting Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NU50CK000556 and 2020 Pass-through City of Chicago, Department of Public Health COVID-19 ? Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Federal Assistance Listing #93.323 County Department ? Cook County Health Finding 2022 ? 006 (Continued) CONTEXT (Continued) Report Period Due Date Submission Date Days Late 3/1/2022-3/31/2022 4/15/2022 8/30/2022 137 7/1/2022-7/31/2022 8/15/2022 8/30/2022 15 In addition, for the remaining two reports covering the periods from 10/1/2022 to 10/31/2022 and 11/1/2022 to 11/30/2022, we noted expenditures of $7,126 and $7,608 respectively, included on the reports, which were not recorded as federal grant expenditures in the Oracle accounting system. Consequently, this resulted in an adjustment to the schedule of expenditures of federal awards to not only include these amounts, but the total grant expenditures incurred totaling $931,606 under the federal program during 2022. IDENTIFICATION OF REPEATED FINDINGS Repeated (Prior Finding No. 2021-004) RECOMMENDATION We recommend that CCH develop and implement procedures to ensure reports are submitted in a timely manner and in compliance with its grant agreements. A compliance calendar of all grants reporting due dates should be maintained to assist with ensuring compliance with reporting requirements. In addition, we recommend CCH ensure all expenditures included on grant reports are properly reported in the schedule of expenditures of federal awards. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 63.
Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, ?The non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and terms and conditions of the Federal award.? Subpart E ? Cost Principles, Section 200.403 states costs must meet the following general criteria in order to be allowable under Federal awards: ?(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. ?(g) Be adequately documented.? In addition, Subpart E ? Cost Principles, Section 200.430 (i)(1) Standards for Documentation of Personal Expenses, states, ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; and (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities.? CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not maintain adequate controls over allowable costs as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from Program Leads and the Accounts Payable unit not following the established requirements for properly supporting invoices for services provided. The invoices that were attached in EBS Oracle were insufficient as required by the established County Policy. SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Inadequate Controls over Allowable Costs Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH23IP922637 and 2021 Pass-through the Illinois Department of Public Health COVID-19 ? Immunization Cooperative Agreements, Federal Assistance Listing #93.268 County Department ? Department of Public Health Finding 2022 ? 004 (Continued) EFFECT The failure to maintain adequate support and/or documentation evidencing the review of actual time spent by employees on the program is a violation of federal regulations and could result in additional payroll costs being charged to the federally funded program. QUESTIONED COSTS None. CONTEXT During our test of 35 expenditures, we were provided invoices supporting the total charges to the program. However, we noted 12 of the invoices reviewed included payroll related charges, of which we were unable to determine that DPH reviewed the detailed payroll records (such as time and effort reports) of those employees charged to the grant to verify that the related services were performed and were within the period specified on the invoices. This was due to the fact, that information was not maintained in the Oracle accounting system. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH develop and implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supporting documentation maintained in accordance with federal regulations and the County?s policy. Once procedures are developed, adequate staff training should be conducted to ensure all program/grant finance personnel are familiar with the requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 62.