Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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 ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,765,946 $2,765,946 $2,765,946 $2,765,946 $2,765,946 Cause: Management asserted that the agreement had been in place for greater than 10 years and had no reason to be updated. Management has also asserted that they do not have access to submit the FFATA reports. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-005. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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 ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,765,946 $2,765,946 $2,765,946 $2,765,946 $2,765,946 Cause: Management asserted that the agreement had been in place for greater than 10 years and had no reason to be updated. Management has also asserted that they do not have access to submit the FFATA reports. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-005. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency, Instance of Noncompliance Criteria: The Consolidated Appropriations Act, 2021, for Emergency Rental Assistance Program (ERA) requires the entity to establish and document their policies and procedures for determining a household?s eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. Within those policies, the grantee is required to specify under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance, and in such cases, grantees must have in place reasonable validation or fraud-prevention procedures to prevent abuse. Condition: The County?s policy and procedures for eligibility determination did not incorporate policies and procedures specifying under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance. Cause: The County did not formulate complete policies and procedures for the program. Effect: The County?s policies and procedures were incomplete. Questioned Costs: None identified. Context/Sampling: This instance was identified through our review of the County?s policies and procedures. Repeat Finding from Prior Year: No. Recommendation: We recommend the County revise its policies and procedures for the program. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: We noted that reports were submitted for the program did not go through a review process. Furthermore, we identified two instances in which quarterly report amounts were not accurately reported. We identified two instances in which amounts reported were inaccurate. In both instances, we found that the cumulative expenditures reported did not agreed to the underlying accounting records. In one instance, we found that the County incorrectly reported cumulative obligations and cumulative expenditures as zero. Cause: The County did not establish a review and approval process for the reports submitted for the program. Effect: The County?s reports did not go through a review process. Amounts were not accurately reported. Questioned Costs: None noted. Context/Sampling: These instances were identified through our procedures over compliance with the Uniform Guidance for reporting. A sample of 6 (2 quarterly, 4 monthly) reports out of a population of 16 (2 quarterly and 12 monthly) were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County strengthen its internal controls to ensure that reports are subject to review prior to submission and maintain evidence of a review and approval. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1. Reviewing of financial and performance reports as 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 ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: None noted. Context/Sampling: We selected 100% of the County?s subrecipients of the program. $6,177,719 was paid to the subrecipient during the fiscal year. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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 ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,765,946 $2,765,946 $2,765,946 $2,765,946 $2,765,946 Cause: Management asserted that the agreement had been in place for greater than 10 years and had no reason to be updated. Management has also asserted that they do not have access to submit the FFATA reports. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-005. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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 ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,765,946 $2,765,946 $2,765,946 $2,765,946 $2,765,946 Cause: Management asserted that the agreement had been in place for greater than 10 years and had no reason to be updated. Management has also asserted that they do not have access to submit the FFATA reports. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-005. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency, Instance of Noncompliance Criteria: The Consolidated Appropriations Act, 2021, for Emergency Rental Assistance Program (ERA) requires the entity to establish and document their policies and procedures for determining a household?s eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. Within those policies, the grantee is required to specify under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance, and in such cases, grantees must have in place reasonable validation or fraud-prevention procedures to prevent abuse. Condition: The County?s policy and procedures for eligibility determination did not incorporate policies and procedures specifying under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance. Cause: The County did not formulate complete policies and procedures for the program. Effect: The County?s policies and procedures were incomplete. Questioned Costs: None identified. Context/Sampling: This instance was identified through our review of the County?s policies and procedures. Repeat Finding from Prior Year: No. Recommendation: We recommend the County revise its policies and procedures for the program. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) requires that the non-federal entity must 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: We noted that reports were submitted for the program did not go through a review process. Furthermore, we identified two instances in which quarterly report amounts were not accurately reported. We identified two instances in which amounts reported were inaccurate. In both instances, we found that the cumulative expenditures reported did not agreed to the underlying accounting records. In one instance, we found that the County incorrectly reported cumulative obligations and cumulative expenditures as zero. Cause: The County did not establish a review and approval process for the reports submitted for the program. Effect: The County?s reports did not go through a review process. Amounts were not accurately reported. Questioned Costs: None noted. Context/Sampling: These instances were identified through our procedures over compliance with the Uniform Guidance for reporting. A sample of 6 (2 quarterly, 4 monthly) reports out of a population of 16 (2 quarterly and 12 monthly) were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County strengthen its internal controls to ensure that reports are subject to review prior to submission and maintain evidence of a review and approval. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1. Reviewing of financial and performance reports as 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 ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: None noted. Context/Sampling: We selected 100% of the County?s subrecipients of the program. $6,177,719 was paid to the subrecipient during the fiscal year. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.