Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Procurement Questioned costs: $25,625 Condition?Contrary to federal regulations and County policies and procedures, the County inappropriately used sole source procurement for a contract paid for with federal program monies. Specifically, the Public Works Department, which initiated the sole source procurement, and the County?s former procurement officer who approved the sole source procurement inappropriately used a sole source procurement for a $25,625 contract for hauling dirt for the County Fair?s arena paid for with federal program monies, failing to ensure multiple sources for the service did not exist and to appropriately document the sole source justification in the contract file. This inappropriate sole source purchase comprised 3.6 percent of the program?s total federal award expenditures of $707,004 in fiscal year 2022. Effect?The County?s inappropriate use of a sole source procurement increased the County?s risk of not receiving the most advantageous price for the service purchased with federal monies. Therefore, the County may have inappropriately decreased federal program monies available for other program activities. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County?s current procurement officer reported that the former procurement officer is no longer employed with the County and, therefore, did not know why the County?s sole source procurement procedures were not followed, documented, and enforced. Criteria?Federal regulations permit noncompetitive purchases using federal program monies only in certain circumstances, such as when there is only a single source for purchasing goods/services, and require the County to establish and follow written policies and procedures that conform with the purchasing requirements of the federal Uniform Guidance (2 CFR ?200.318 and .320[c][2]). Further, County policies and procedures require sole source procurement to be avoided when possible and require the County procurement officer and departments to conduct a good-faith search for available sources and, if there is only one source for the goods or services being purchased, to document the determination for using sole source procurements prior to making such purchases and include it in the contract file (Gila County. [2019.] Procurement Policy, Section 8, Part C.). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Require the Public Works Department and procurement officer to follow County policies and procedures for determining and documenting each sole source procurement only after conducting a good-faith search for available sources and concluding there is only a single source and include it in the contract file. 2. Annually, train all County employees with purchasing responsibilities, including the Public Works Department and procurement officer, on the County?s policies and procedures for determining and documenting sole source procurements. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition?The County?s Finance Department (Department) did not review and approve all 4 federal program reports (progress reports), including 1 interim and 3 project and expenditure reports, before submitting them to the federal agency. Specifically, the Department was advanced $10,492,363 of program monies, and of this amount, the Department reported expenditures totaling $707,004 in progress reports as of June 30, 2022. However, the Department did not perform an independent review and approval of these required progress reports to ensure the $707,004 of reported expenditures was accurate, agreed to County records, and contained only allowable expenditures. Our testing of the 3 progress reports found the following inaccuracies: ? Both a $631,385 understatement and overstatement, respectively, of program expenditures and obligations on the December 31, 2021 and March 31, 2022, progress reports because the County reported the expenditures and obligations in the wrong quarter. ? A $99,811 overstatement of cumulative program obligations the County reported on both the December 31, 2021 and March 31, 2022, progress reports. ? An overstatement of $555,767 and an understatement of $75,618, respectively, of current and cumulative program expenditures the County reported on the June 30, 2022, progress report. ? Overstatements of $655,578 and $24,193, respectively, of current and cumulative program obligations the County reported on the June 30, 2022, progress report. Effect?The Department?s reporting inaccurate and erroneous program information results in the federal agency being unable to rely on the reports to effectively monitor the Department?s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program?s success. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County did not have policies and procedures requiring the Department to perform and document an independent review and approval of the program?s reports before submitting them to the federal agency. Although the Department reported that it had performed independent reviews and approvals of the reports, it did not document these independent reviews and approvals, nor did these reviews detect the errors we noted above. Criteria?Federal agency guidance requires the County to verify and confirm that all program information that it reports is accurate and approved before submitting it.1 Additionally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County?s management should: 1. Develop policies and procedures requiring the Department to: a. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. b. Reconcile program expenditure amounts reported to the County?s accounting records. 2. Adjust or resubmit reports for errors detected on reports the Department already submitted to the federal agency or work with the federal agency so that it is informed of errors on previously submitted reports. 3. Train Department employees responsible for preparing and reviewing reports on what information to gather to prepare the reports and on the County?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of the Treasury. (2022.) State and Local Fiscal Recovery Funds: Project and Expenditure Report User Guide, Section IV, Part i.?Subawards or Direct Payments. Retrieved on 4/6/2023 from https://home.treasury.gov/system/files/136/April-2022-PE-Report-User-Guide.pdf.
Assistance Listings number and name: 93.137 COVID-19 Community Programs to Improve Minority Health Grant Program Award number and years: 1 CPIMP211254-01-00, July 2, 2021 through June 30, 2023; Federal agency: U.S. Department of Health and Human Services Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal guidance and the County?s federal grant award terms, the County?s Health and Emergency Management Department and Finance Department did not prepare and submit timely and accurate program information to the federal grantor agency for monitoring and expense reimbursement. Specifically, the departments submitted the first 2 required quarterly reports to the federal agency in February 2022, which was 95 and 11 days later than required for the September 30, 2021 and December 31, 2021, reports, respectively. The departments also reported inaccurate information in all 4 quarterly reports they submitted. Specifically, they omitted information related to cash disbursements for the first 2 quarterly reports in the amounts of $507,363 and $359,964, respectively, resulting in cash on hand being overstated. Further, they reported inaccurate information on the final 2 quarterly reports in the amounts of $507,363 and $14,644, respectively, related to multiple line items in the reports. Effect?The departments? reporting untimely program information delayed the County?s receiving federal reimbursement for program expenditures it incurred totaling $867,327 until March 2022. Had the departments submitted the first 2 reports on time, the County could have received an initial reimbursement of $507,363 in October 2021 and a second reimbursement of $359,964 in January 2022. Also, the departments? reporting untimely and inaccurate program information negatively impacts the federal agency?s ability to effectively monitor the County?s program administration and compliance with program requirements, prevent and detect fraud, and evaluate the program?s success. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County lacked policies and procedures requiring the departments to perform and document an independent review and approval of federal program reports before submitting them to the federal agency. Although the Departments did not have policies and procedures requiring a review, they had assigned an employee to perform a review and submit the reports. However, this employee was no longer employed with the County, and therefore, the departments did not know why the reports were submitted late and the errors were not detected. Criteria?Federal agency guidance and the County?s grant award terms require the departments to submit to the federal agency quarterly program information reports to request reimbursement of program expenditures the County incurs during each quarter, no later than 30 days after each quarter?s end. Further, the guidance and award terms require the departments to complete the reports using the federal agency?s financial reporting instructions.1 Finally, federal regulation requires the County's establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County?s management should: 1. Develop and implement policies and procedures requiring the departments to: a. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. b. Submit reports on time. 2. Annually train the departments? employees who are responsible for preparing and reviewing reports regarding the information required to be gathered and documented in the County?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Health and Human Services (HHS). (2010.) Federal Financial Report Instructions. Retrieved on 4/12/2023 from https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/sf_425_instructions.pdf.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Procurement Questioned costs: $25,625 Condition?Contrary to federal regulations and County policies and procedures, the County inappropriately used sole source procurement for a contract paid for with federal program monies. Specifically, the Public Works Department, which initiated the sole source procurement, and the County?s former procurement officer who approved the sole source procurement inappropriately used a sole source procurement for a $25,625 contract for hauling dirt for the County Fair?s arena paid for with federal program monies, failing to ensure multiple sources for the service did not exist and to appropriately document the sole source justification in the contract file. This inappropriate sole source purchase comprised 3.6 percent of the program?s total federal award expenditures of $707,004 in fiscal year 2022. Effect?The County?s inappropriate use of a sole source procurement increased the County?s risk of not receiving the most advantageous price for the service purchased with federal monies. Therefore, the County may have inappropriately decreased federal program monies available for other program activities. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County?s current procurement officer reported that the former procurement officer is no longer employed with the County and, therefore, did not know why the County?s sole source procurement procedures were not followed, documented, and enforced. Criteria?Federal regulations permit noncompetitive purchases using federal program monies only in certain circumstances, such as when there is only a single source for purchasing goods/services, and require the County to establish and follow written policies and procedures that conform with the purchasing requirements of the federal Uniform Guidance (2 CFR ?200.318 and .320[c][2]). Further, County policies and procedures require sole source procurement to be avoided when possible and require the County procurement officer and departments to conduct a good-faith search for available sources and, if there is only one source for the goods or services being purchased, to document the determination for using sole source procurements prior to making such purchases and include it in the contract file (Gila County. [2019.] Procurement Policy, Section 8, Part C.). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County should: 1. Require the Public Works Department and procurement officer to follow County policies and procedures for determining and documenting each sole source procurement only after conducting a good-faith search for available sources and concluding there is only a single source and include it in the contract file. 2. Annually, train all County employees with purchasing responsibilities, including the Public Works Department and procurement officer, on the County?s policies and procedures for determining and documenting sole source procurements. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy.
Assistance Listings number and name: 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award number and year: SLFRP0665, March 3, 2021 through December 31, 2026 Federal agency: U.S. Department of the Treasury Compliance requirement: Reporting Questioned costs: Not applicable Condition?The County?s Finance Department (Department) did not review and approve all 4 federal program reports (progress reports), including 1 interim and 3 project and expenditure reports, before submitting them to the federal agency. Specifically, the Department was advanced $10,492,363 of program monies, and of this amount, the Department reported expenditures totaling $707,004 in progress reports as of June 30, 2022. However, the Department did not perform an independent review and approval of these required progress reports to ensure the $707,004 of reported expenditures was accurate, agreed to County records, and contained only allowable expenditures. Our testing of the 3 progress reports found the following inaccuracies: ? Both a $631,385 understatement and overstatement, respectively, of program expenditures and obligations on the December 31, 2021 and March 31, 2022, progress reports because the County reported the expenditures and obligations in the wrong quarter. ? A $99,811 overstatement of cumulative program obligations the County reported on both the December 31, 2021 and March 31, 2022, progress reports. ? An overstatement of $555,767 and an understatement of $75,618, respectively, of current and cumulative program expenditures the County reported on the June 30, 2022, progress report. ? Overstatements of $655,578 and $24,193, respectively, of current and cumulative program obligations the County reported on the June 30, 2022, progress report. Effect?The Department?s reporting inaccurate and erroneous program information results in the federal agency being unable to rely on the reports to effectively monitor the Department?s program administration, including its compliance with program requirements and ability to prevent and detect fraud, and to evaluate the program?s success. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County did not have policies and procedures requiring the Department to perform and document an independent review and approval of the program?s reports before submitting them to the federal agency. Although the Department reported that it had performed independent reviews and approvals of the reports, it did not document these independent reviews and approvals, nor did these reviews detect the errors we noted above. Criteria?Federal agency guidance requires the County to verify and confirm that all program information that it reports is accurate and approved before submitting it.1 Additionally, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County?s management should: 1. Develop policies and procedures requiring the Department to: a. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. b. Reconcile program expenditure amounts reported to the County?s accounting records. 2. Adjust or resubmit reports for errors detected on reports the Department already submitted to the federal agency or work with the federal agency so that it is informed of errors on previously submitted reports. 3. Train Department employees responsible for preparing and reviewing reports on what information to gather to prepare the reports and on the County?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of the Treasury. (2022.) State and Local Fiscal Recovery Funds: Project and Expenditure Report User Guide, Section IV, Part i.?Subawards or Direct Payments. Retrieved on 4/6/2023 from https://home.treasury.gov/system/files/136/April-2022-PE-Report-User-Guide.pdf.
Assistance Listings number and name: 93.137 COVID-19 Community Programs to Improve Minority Health Grant Program Award number and years: 1 CPIMP211254-01-00, July 2, 2021 through June 30, 2023; Federal agency: U.S. Department of Health and Human Services Compliance requirement: Reporting Questioned costs: Not applicable Condition?Contrary to federal guidance and the County?s federal grant award terms, the County?s Health and Emergency Management Department and Finance Department did not prepare and submit timely and accurate program information to the federal grantor agency for monitoring and expense reimbursement. Specifically, the departments submitted the first 2 required quarterly reports to the federal agency in February 2022, which was 95 and 11 days later than required for the September 30, 2021 and December 31, 2021, reports, respectively. The departments also reported inaccurate information in all 4 quarterly reports they submitted. Specifically, they omitted information related to cash disbursements for the first 2 quarterly reports in the amounts of $507,363 and $359,964, respectively, resulting in cash on hand being overstated. Further, they reported inaccurate information on the final 2 quarterly reports in the amounts of $507,363 and $14,644, respectively, related to multiple line items in the reports. Effect?The departments? reporting untimely program information delayed the County?s receiving federal reimbursement for program expenditures it incurred totaling $867,327 until March 2022. Had the departments submitted the first 2 reports on time, the County could have received an initial reimbursement of $507,363 in October 2021 and a second reimbursement of $359,964 in January 2022. Also, the departments? reporting untimely and inaccurate program information negatively impacts the federal agency?s ability to effectively monitor the County?s program administration and compliance with program requirements, prevent and detect fraud, and evaluate the program?s success. The County is also at risk that this finding applies to other federal programs that it administers. Cause?The County lacked policies and procedures requiring the departments to perform and document an independent review and approval of federal program reports before submitting them to the federal agency. Although the Departments did not have policies and procedures requiring a review, they had assigned an employee to perform a review and submit the reports. However, this employee was no longer employed with the County, and therefore, the departments did not know why the reports were submitted late and the errors were not detected. Criteria?Federal agency guidance and the County?s grant award terms require the departments to submit to the federal agency quarterly program information reports to request reimbursement of program expenditures the County incurs during each quarter, no later than 30 days after each quarter?s end. Further, the guidance and award terms require the departments to complete the reports using the federal agency?s financial reporting instructions.1 Finally, federal regulation requires the County's establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR ?200.303). Recommendations?The County?s management should: 1. Develop and implement policies and procedures requiring the departments to: a. Perform and document an independent review and approval of all federal program reports before submitting them to the federal agency to ensure the reports are accurate, agree to County records, and contain only allowable expenditures. b. Submit reports on time. 2. Annually train the departments? employees who are responsible for preparing and reviewing reports regarding the information required to be gathered and documented in the County?s policies and procedures. The County?s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. 1 U.S. Department of Health and Human Services (HHS). (2010.) Federal Financial Report Instructions. Retrieved on 4/12/2023 from https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/sf_425_instructions.pdf.