FAC Explorer

Audit 51115

FY End
2022-12-31
Total Expended
$5.83M
Findings
8
Programs
34
Organization: Oconto County, Wisconsin (WI)
Year: 2022 Accepted: 2023-09-10
Auditor: Cliftonlarsonallen LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
47657 2022-003 Material Weakness - I
47658 2022-003 Material Weakness - I
47659 2022-002 Material Weakness - I
47660 2022-003 Material Weakness - I
624099 2022-003 Material Weakness - I
624100 2022-003 Material Weakness - I
624101 2022-002 Material Weakness - I
624102 2022-003 Material Weakness - I

Programs

ALN Program Spent Major Findings
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $610,580 Yes 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $297,610 Yes 2
93.778 Medical Assistance Program $293,129 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $142,023 - 0
93.667 Social Services Block Grant $116,397 - 0
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $100,246 - 0
10.912 Environmental Quality Incentives Program $94,638 - 0
93.575 Child Care and Development Block Grant $63,589 - 0
15.662 Great Lakes Restoration $56,938 - 0
97.042 Emergency Management Performance Grants $55,061 - 0
84.069 Public Health Emergency Preparedness $51,441 - 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $47,060 - 0
93.268 Immunization Cooperative Agreements $45,214 - 0
21.219 Recreational Trails Program $45,000 - 0
93.556 Promoting Safe and Stable Families $42,827 - 0
66.181 Special Education-Grants for Infants and Families $36,543 - 0
15.658 Natural Resource Damage Assessment, Restoration and Implementation $35,270 - 0
20.219 Recreational Trails Program $28,100 - 0
21.027 Coronavirus State and Local Fiscal Recovery Funds $25,179 Yes 1
93.767 Children's Health Insurance Program $23,509 - 0
93.658 Foster Care_title IV-E $21,954 - 0
20.469 Great Lakes Program $19,781 - 0
93.090 Guardianship Assistance $18,908 - 0
21.019 Coronavirus Relief Fund $17,546 - 0
93.994 Maternal and Child Health Services Block Grant to the States $13,829 - 0
93.958 Block Grants for Community Mental Health Services $13,353 - 0
93.959 Block Grants for Prevention and Treatment of Substance Abuse $12,242 - 0
93.991 Preventive Health and Health Services Block Grant $6,223 - 0
10.561 Special Supplemental Nutrition Program for Women, Infants, and Children $3,758 - 0
16.607 Bulletproof Vest Partnership Program $1,958 - 0
93.645 Stephanie Tubbs Jones Child Welfare Services Program $1,337 - 0
93.659 Adoption Assistance $681 - 0
93.558 Temporary Assistance for Needy Families $405 - 0
93.563 Child Support Enforcement $-42,590 - 0

Contacts

Name Title Type
MT49VJLMSDC5 Lisa Sherman Auditee
9208347111 Leah Lasecki Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in Oconto County's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Assistance Listing 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year end consists of federal and state program expenditures scheduled for reimbursement to Oconto County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded Oconto County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The accompanying Schedules of Expenditures of Federal and State Awards for Oconto County, Wisconsin are presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the State Single Audit Guidelines issued by the Wisconsin Department of Administration.The Schedules of Expenditures of Federal and State Awards include all federal and state awards of Oconto County. Because the schedules present only a selected portion of the operations of Oconto County, it is not intended to and does not present the financial position, changes in net position, or cash flows of Oconto County.
Title: OVERSIGHT AGENCIES Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in Oconto County's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Assistance Listing 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year end consists of federal and state program expenditures scheduled for reimbursement to Oconto County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded Oconto County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The federal and state oversight agencies for Oconto County are as follows:Federal U.S. Department of CommerceState Wisconsin Department of Health Services
Title: TITLE 19 MEDICAL ASSISTANCE PAYMENTS Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in Oconto County's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Assistance Listing 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year end consists of federal and state program expenditures scheduled for reimbursement to Oconto County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded Oconto County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Schedules of Expenditures of Federal and State Awards do not include recorded revenues of $216,571 received by Oconto County for Title 19 Medical Assistance programs. The payments are considered a contract for services between the State and Oconto County and therefore are not reported as federal or state awards.
Title: STATE DIRECT PAYMENTS Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in Oconto County's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Assistance Listing 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year end consists of federal and state program expenditures scheduled for reimbursement to Oconto County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded Oconto County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. Payments made directly to recipients and vendors by the State of Wisconsin under the FoodShare Wisconsin program on behalf of Oconto County are not included in the Schedules of Expenditures of Federal and State Awards.
Title: STATE OF WISCONSIN COMMUNITY AIDS REPORTING SYSTEM Accounting Policies: Revenues and expenditures in the schedules are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in Oconto County's 2022 fund financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance for all awards with the exception of Assistance Listing 21.019, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. Accrued revenue at year end consists of federal and state program expenditures scheduled for reimbursement to Oconto County in the succeeding year while unearned revenue represents advances for federal and state programs that exceed recorded Oconto County expenditures. Because of subsequent program adjustments, these amounts may differ from the prior year's ending balances. De Minimis Rate Used: N Rate Explanation: The auditee did not use the de minimis cost rate. The Wisconsin Departments of Health Services (DHS) and Children and Families (DCF) utilize the Community Aids Reporting System (CARS) and the System for Payments and Reports of Contracts (SPARC) for reimbursing Oconto County for various federal and state program expenditures. The expenditures reported on the Schedules of Expenditures of Federal and State Awards for various DHS & DCF programs agree with the expenditures reported on the May 2023 CARS for the Human Services and Public Health Departments, and the December 2022 SPARC for Child Support and Child Care programs.

Finding Details

Finding 2022-003
2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.
Finding 2022-003
2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.
Finding 2022-002
2022-002 Procurement Federal Agency: U.S. Department of Health and Human Services Federal Program Name: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Number: 155802 Federal Award Identification Number and Year: NU50CK000534 and 2020 Award Period: October 1, 2020 ? October 31, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ?200.320. The nonFederal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the County's written procurement policy on approval thresholds and controls. Condition: The County did not follow their established controls related to ensuring procurement policies were followed. Questioned Costs: $231,169 Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with procurement requirements. Cause: The Human Services department at the County does not have established procedures to verify procurement policies are followed prior to entering into a procurement transaction with a vendor in which federal funds are going to be used. Effect: The County is not in compliance with procurement requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed. View of Responsible Officials: There is no disagreement with the finding.
Finding 2022-003
2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.
Finding 2022-003
2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.
Finding 2022-003
2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.
Finding 2022-002
2022-002 Procurement Federal Agency: U.S. Department of Health and Human Services Federal Program Name: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Number: 155802 Federal Award Identification Number and Year: NU50CK000534 and 2020 Award Period: October 1, 2020 ? October 31, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ?200.320. The nonFederal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the County's written procurement policy on approval thresholds and controls. Condition: The County did not follow their established controls related to ensuring procurement policies were followed. Questioned Costs: $231,169 Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with procurement requirements. Cause: The Human Services department at the County does not have established procedures to verify procurement policies are followed prior to entering into a procurement transaction with a vendor in which federal funds are going to be used. Effect: The County is not in compliance with procurement requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed. View of Responsible Officials: There is no disagreement with the finding.
Finding 2022-003
2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.