Audit 409334

2023-001 Improve Internal Controls and Documentation over Allowable Costs and Eligibility Determinations Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Additionally, 2 CFR 200.334 requires the retention of records and supporting documentation to demonstrate eligibility determinations and allowability of expenditures under the program. Condition and Context During our audit, we tested a sample of 40 selections for allowable costs, as well as a sample of 40 for individual eligibility determinations under the program in which 38 selections were leveraged between the two tests. For 1 of the items selected for testing under allowable cost compliance and eligibility requirements, the County was unable to provide some of the required supporting documentation to demonstrate that individuals met the program’s eligibility requirements. However, lease agreements supporting the amount ultimately paid to the individual were provided to support allowability. The documentation was retained in an online portal to which the County no longer had access at the time of our audit procedures. Cause The County did not establish sufficient procedures or controls to ensure ongoing access to required supporting documentation maintained in the external portal used for program administration. Effect or Potential Effect Due to the weakness in internal controls noted above, the County could not demonstrate compliance with eligibility requirements for the sampled transaction. This also constitutes noncompliance with record retention requirements and impairs the ability for sufficient procedures to be performed over the program. Questioned Costs None reported. Identification as a Repeat Finding This is a repeat of finding 2022-002. Recommendation The County should implement policies and procedures to ensure required documentation for the program is retained in a manner that ensures continued access, even if administration platforms change or external portals are no longer accessible. The County should also periodically verify that it retains all necessary support for program transactions as required under federal regulations. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-002 Improve Internal Controls over Reporting Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Emergency Rental Assistance Program Assistance Listing Number: 21.023 Award Year: 2022 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Per 2 CFR 200.303, the County is required to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and the terms and conditions of the award. Program guidance requires timely and accurate submission of quarterly financial and performance reports, as well as monthly performance reports, to the U.S. Department of the Treasury in accordance with established deadlines. Condition and Context During our testing of the reporting compliance requirement for ERA 1 and ERA 2 awards over the quarterly financial reports, quarterly performance reports and monthly performance reports, we noted the following exceptions: • Of the 2 quarterly financial reports (SF-425) tested, both ERA 2 reports for quarter ends 9/30/2022 and 12/31/2022 were submitted after the required deadline. • Of the 2 quarterly performance reports tested, both ERA 2 reports for quarter ends 9/30/2022 and 12/31/2022 were submitted after the required deadline. • Of the 1 final report tested, the ERA 1 report due on 1/30/2023 was submitted after the required deadline. Cause The County did not establish sufficient procedures or controls to ensure timely submission of all required reports or retention of sufficient evidence to support timeliness of filing. In addition, the County did not have a contingency process in place to address system errors affecting timely reporting. Effect or Potential Effect Due to the weakness in internal controls noted above, there is an increased risk that required program information may not be reported to the granting agency in a timely manner consistent with federal reporting requirements. Additionally, the lack of supporting documentation impedes the ability to verify compliance with reporting deadlines. Questioned Costs None reported. Identification as a Repeat Finding This is a repeat of finding 2022-003. Recommendation The County should strengthen internal controls in place over the timely submission and documentation of required reports for the program. This should include maintaining sufficient evidence of the date and method of submission and considering the implementation of backup procedures in the event system issues affect timely reporting. The County should ensure any delays are documented and, if necessary, approved by the granting agency in writing. Views of Responsible Official and Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

2023-003 Improve Compliance with Procurement Contract Provisions Federal Program Information Federal Agency: Department of the Treasury Award Name: COVID-19 Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Award Year: 2021 Compliance Requirement: Procurement Type of Finding Compliance Internal Control over Compliance – Significant Deficiency Criteria or Specific Requirement Recipients of federal awards must comply with the procurement requirements of 2 CFR Part 200, including the contract provisions required by Appendix II to 2 CFR Part 200. Contracts funded with federal awards must include all applicable provisions prescribed by Appendix II, such as termination for cause and convenience, Equal Employment Opportunity, Davis-Bacon Act requirements (when applicable), Contract Work Hours and Safety Standards Act requirements, rights to inventions, Clean Air Act and Federal Water Pollution Control Act provisions, Byrd Anti-Lobbying Amendment requirements, and procurement of recovered materials, as applicable. Condition and Context During testing of vendor contracts charged to the award, we reviewed 2 executed contracts and identified that both contracts that did not contain one or more contract provisions required by Appendix II to 2 CFR Part 200. Missing provisions varied by contract and included federally required clauses applicable to the nature and dollar amount of the procurement. The County did not have a control in place to ensure that contracts funded with federal awards were reviewed for inclusion of all required federal contract provisions prior to execution. Cause Management had not established a formal contract review process designed to verify compliance with Appendix II to 2 CFR Part 200 prior to executing vendor agreements funded by federal awards. Effect or Potential Effect Lack of inclusion of all required federal contract provisions increases the risk of noncompliance with Uniform Guidance and could lead to disputes or enforcement issues if regulatory or compliance matters arise. Questioned Costs No questioned costs are reported as the services were procured appropriately and ultimately deemed allowable. Identification as a Repeat Finding This is not a repeat finding. Recommendation Management should enhance its procurement procedures to ensure all contracts funded by federal awards include every provision required by Appendix II to 2 CFR Part 200 as applicable. Regular review of contract templates and procurement checklists should be implemented to support compliance. Views of Responsible Official Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.