Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Emergency Rental Assistance Program Federal Financial Assistance Listing Number: 21.023 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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. 2 CFR Section 200.01 of the Uniform Guidance states that the County may report charges on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instance where reports were prepared on the cash basis, but reports indicated that the costs were reported on the accrual basis of accounting: ? Two (2) out of the three (3) reports for the HCA. Corrective action of prior year finding was implemented mid-year. Cause: The HCA department reported amounts on cash basis, but the form identified the basis for the report as ?accrual?. The HCA department review process and certification of the report did not identify the discrepancy. Effect: The County?s control was not consistently followed, which applies the basis of accounting on a consistent basis. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) reports were selected for report testing. Repeat Finding from Prior Years: Yes, Finding 2021-005. Recommendation: We recommend the HCA adhere to their policies and apply the same basis of accounting on a consistent basis for the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Supplemental Nutrition Assistance Program (SNAP) Cluster Federal Financial Assistance Listing Number: 10.561 Federal Grantor: U.S. Department of Agriculture Passed-Through: California Department of Social Services Award No. and Year: 217CACA4S2514, 227CACA4S2514, 217CACA4Q7503, 227CACA4Q7503, 217CACA4S2519, 227CACA4S2519, 217CACA4S2520, 227CACA4S2520, 217CACA5S9018, 217CACA6F1003, 227CACA7F1003 and 2022 Compliance Requirements: Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Criteria: 7 CFR sections 272.10 and 277.18 require State agencies to automate their SNAP operations and computerize their systems for obtaining, maintaining, utilizing, and transmitting information concerning SNAP. This includes: (1) accurately and completely processing and storing all case file information for eligibility determination and benefit calculation; (2) providing an automatic cutoff of households at the end of their certification period unless recertified; and (3) generating data necessary to meet federal issuance and reconciliation reporting requirements. Condition: In establishing a new case, the client is certified to receive benefits for a one-year period (certification period). The intake and certification process require that information on the CF-37 and SAWS 2 be obtained to determine eligibility and assist in the benefit calculation. Further, prior to case worker approval of benefits, the Income Eligibility Verification System (IEVS) report is required to be processed in certain circumstances. During our testing of the SSA department?s provisions for special tests and provisions requirements relating to ADP System for SNAP, we noted the following instances: ? For thirteen (13) of forty (40) participants selected for testing, there was no evidence that a case worker reviewed and certified the participants IEVS report. ? For three (3) of forty (40) participants selected for testing, the income verification document used in the benefit calculation was not retained by the department. Cause: The condition is primarily caused by the SSA department not following policies and procedures in place to ensure the eligibility case files contain documentation to support eligibility and benefit calculations. Effect: Case data may not be current or accurate in the case file or the system, which could lead to initial and continued eligibility errors, inaccurate benefit calculations, and benefit overpayments. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of forty (40) out of one hundred eleven thousand and fifty-one (111,051) participants were selected for special tests and provisions relating to ADP System for SNAP. The condition above was identified during our testwork of the SSA?s internal controls over special tests and provisions. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its established policies and procedures with regard to initial and ongoing eligibility determination, required documentation and verifications, maintenance of participant files, and ensure that policies and procedures are strictly adhered to by County personnel. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Immunization Cooperative Agreements Federal Financial Assistance Listing Number: 93.268 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 17-10336 A02 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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. 2 CFR Section 200.334, Retention requirements for records, states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report, or, for Federal awards that are renewed quarterly or annually, from the date of submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instances for two (2) out of two (2) reports: ? The performance reports were not reviewed or approved prior to submission to the State. ? The department did not retain any supporting documents for the performance reports. Cause: The HCA department personnel prepared program required performance reports and submitted to the State without retaining evidence that the reports were reviewed and approved by a separate individual prior to submission. The HCA department did not retain any supporting documents for the performance reports submitted. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual prior to submission to the State. Additionally, the HCA department did not adhere to their policies and procedures in place requiring record retention of supporting documentation. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) performance reports were selected for report testing for the Immunization Cooperative Agreements program. Repeat Finding from Prior Years: No. Recommendation: We recommend the HCA adhere to their policies and ensure the review and approval of reports are clearly documented prior to the report?s submission and adhere to their policies of record retention of supporting documents for the performance reports submitted to the State. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: ? 2 CFR 200.332(d)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include the information at 2 CFR 200.332(d)(1) through (4). ? 2 CFR 200.332(f) ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 200.501. The California Department of Social Services further clarifies in its County Fiscal Letter No. 21/22 ? 115 that Foster Family Agency (FFA), Group Home, and Short Term Residential Therapeutic Programs (STRTP) are ?considered subrecipients and subject to the same audit requirements and require the same degree of oversight as other subrecipients?. Further, while there are some licensing and oversight functions performed by the state over FFAs, group homes, and STRTPs, ?counties are still ultimately responsible for review of these audits and their findings, any follow-up to ensure compliance, and any other form of monitoring and oversight required by federal and state laws and regulations.? Condition: The County did not have any formal controls or procedures in place for subrecipient monitoring for the Foster Care program. Cause: The County did not maintain procedures to monitor the activities of each subrecipient, or verify that every subrecipient is audited, as required. Effect: The County did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 and did not comply with subrecipient monitoring requirements related to the program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of eight (8) out of 53 subrecipients were sampled, which included six (6) FFA, and two (2) STRTP types. The condition noted above was identified during our procedures related to subrecipient monitoring, and was pervasive to the program. Repeat Findings from Prior Years: No. Recommendation: We recommend that the County implement policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 180.300a, Responsibilities of Participants Regarding Doing Business with Other Persons (and repeated in the California Department of Social Services - County Fiscal Letter No. 21/22 ? 115) counties are required to verify that recipients or contracts have not been suspended or debarred by using the federal SAM (Systems for Award Management). Condition: During our testing from the Foster Care Program of the SSA, we noted for one (1) of the eight (8) subrecipients selected, SSA did not have documentation that the SAM clearance was performed prior to entering the contract with the subrecipient. The County?s policy was to verify subrecipient was not suspended or debarred prior to entering the contract, but the County did not retain evidence of this check prior to entering the contract. Cause: The SSA department did not follow their policy to retain documentation of the verification of the information prior to entering the contract. Effect: The County?s control policies were not consistently followed, which required documentation of the verification prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing from SSA for the Foster Care program. Repeat Findings from Prior Years: No. Recommendation: We recommend that SSA adhere to their procedures required documentation of the SAM check prior to entering the contract. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award No. and Year: 2022 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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: During our testing of the SSA?s provisions for reporting requirements, we noted the following instance where reports were prepared, reviewed, and approved by the same individual: ? Two (2) of four (4) reports for the SSA Cause: The SSA department did not have a segregation of duties over the preparation and review and approval of performance reports. Effect: The County?s control was not consistently followed, which requires reports to be reviewed and approved by a separate individual. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical of four (4) out of twelve (12) reports were selected for reporting testing from SSA. The condition above was identified during our testwork of the SSA?s internal controls over reporting. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA adhere to their policies and ensure segregation of duties over the preparation and review and approval of performance reports. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Medicaid Cluster Federal Financial Assistance Listing Number: 93.778 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Public Health Award No. and Year: 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency in Internal Control Criteria: Title 42 Chapter IV Subchapter C Part 425 Subpart J Section 435.907, Application, states that the agency must accept an application from the applicant, an adult who is in the applicant's household, as defined in ? 435.603(f), or family, as defined in section 36B(d)(1) of the Code, an authorized representative, or if the applicant is a minor or incapacitated, someone acting responsibly for the applicant, and any documentation required to establish eligibility which includes via the internet Web site, by telephone, via mail, in person, and through other commonly available electronic means. Condition: During our testing of the SSA?s provisions for eligibility requirements, we noted for three (3) of sixty (60) samples the department did not retain the participant?s application, which is part of the County?s process and internal control. Cause: The SSA department did not ensure case workers were following the department?s policies and procedures relating to the eligibility determination process. Effect: The County?s control was not consistently followed, which requires case workers to retain the participant?s application. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Non-statistical sample of sixty (60) out of two hundred ninety-four thousand and one hundred sixteen (294,116) participants were selected for eligibility testing. The condition above was identified during our testwork of the SSA?s internal controls over eligibility. Repeat Finding from Prior Years: No. Recommendation: We recommend the SSA department adhere to their policies and ensure Case Workers retain participant applications. View of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: During our testing of Homeland Security Grant Program (HSGP) of the Sheriff-Coroner department?s provisions for evaluating subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward, we noted for two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient?s risk of noncompliance was not documented. Further, onsite reviews were not performed. Cause: The Sheriff-Coroner department did not adhere to established policies and procedures relating to documentation of the risk assessment when a subrecipient contract is awarded. With respect to onsite reviews, these were not performed due to COVID restrictions. Effect: There is an increased risk that the monitoring procedures performed may not address the subrecipient?s risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing from the Sheriff-Coroner department for the Homeland Security Grant Program. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner department follow the implemented policies and procedures to ensure that the required evaluation of the subrecipient?s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Passed-Through: California Office of Emergency Services Award No. and Year: 2019-0035 and 2020; 2020-0095 and 2021 Program: Foster Care Federal Financial Assistance Listing Number: 93.658 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 2201CAFOST and 2022, 2101CAFOST and 2021 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Part 200.331(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for two (2) of two (2) subawards selected for testing from the Homeland Security Grant Program within the Sheriff-Coroner department: ? Federal award identification number ? Identification of whether the award is research and development ? Indirect cost rate for the federal award The following information was not provided at the time of the subaward for seven (7) of eight (8) subawards selected for testing from the Social Services Agency?s (SSA) department for the Foster Care program: ? Subrecipient?s unique entity identifier ? Federal award identification number ? Federal award date of award to recipient by the Federal agency ? Subaward period of performance ? Amount of federal funds obligated to the subrecipient ? Amount of federal funds committed to the subrecipient ? Federal award project description ? Name of federal awarding agency ? CFDA number ? Identification of whether the award is research and development ? Indirect cost rate Cause: The Sheriff-Coroner and SSA departments procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients. Effect: The Sheriff-Coroner and SSA departments did not identify the required elements of the subaward to the subrecipients at the time of the subaward, increasing the risk of noncompliance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of two (2) subrecipients were selected for subrecipient monitoring testing for HSGP ? Sheriff-Coroner department. A non-statistical sample of eight (8) of fifty-three (53) subrecipients were selected for subrecipient monitoring testing for the Foster Care program ? SSA. Repeat Finding from Prior Years: No. Recommendation: We recommend that the Sheriff-Coroner and SSA departments modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Emergency Rental Assistance Program Federal Financial Assistance Listing Number: 21.023 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states 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. 2 CFR Section 200.01 of the Uniform Guidance states that the County may report charges on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Condition: During our testing of the HCA?s provisions for reporting requirements, we noted the following instance where reports were prepared on the cash basis, but reports indicated that the costs were reported on the accrual basis of accounting: ? Two (2) out of the three (3) reports for the HCA. Corrective action of prior year finding was implemented mid-year. Cause: The HCA department reported amounts on cash basis, but the form identified the basis for the report as ?accrual?. The HCA department review process and certification of the report did not identify the discrepancy. Effect: The County?s control was not consistently followed, which applies the basis of accounting on a consistent basis. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) reports were selected for report testing. Repeat Finding from Prior Years: Yes, Finding 2021-005. Recommendation: We recommend the HCA adhere to their policies and apply the same basis of accounting on a consistent basis for the program. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: The OMB Approved Award No. 1505-0271 requires that reports submitted to the federal awarding agency include all activity of the reporting period, and are supported by applicable accounting or performance records. The County of Orange (the County) must submit quarterly Project and Expenditure Reports that contain costs incurred during the covered period. Critical information includes: ? Obligations and Expenditures o Current period obligation o Cumulative obligation o Current period expenditure o Cumulative expenditure ? Subawards ? Detailed information on any loans issued; contracts and grants awarded; transfers made to other government entities; and direct payments made by the recipient that are greater than $50,000. For amounts less than $50,000, the recipient must report in the aggregate for these same categories of loans issued; contracts and grants awarded; transfers made to other government entities and direct payments made by the recipient. Condition: Expenditure information was materially different from expenditures reported on the SEFA. This was due to the County identifying additional expenditures after year-end, related to the June 30, 2022 fiscal year. Cause: The County prepared the Project and Expenditure Reports as of a point in time, but internal controls did not allow for consistent reporting or expenditure recognition, to avoid material variances. Effect: Expenditure information in the Project and Expenditure Reports for December 2021, March 2022, and June 2022 reflected modified cash basis expenditures at a point in time, but contained material differences from the amounts included in the SEFA. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of three (3) out of four (4) Project and Expenditure Reports submitted during the year were selected for reporting testing. The cumulative impact is as follows: ? Cumulative expenditure o Reported - $89,613,061 o Per audit/supporting records - $296,907,350, a difference of $207,294,289 Repeat Findings from Prior Years: No. Recommendation: We recommend the County enhance internal controls to ensure Project and Expenditure Reports are prepared in accordance with governing requirements, and updated timely if revisions are made by the County, to avoid material variances to the underlying expenditures reported on the SEFA. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement and Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Criteria: 2 CFR section 200.303(a), Internal Controls, states 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. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The 2022 Compliance Supplement states: Non-Federal 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 non-procurement 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 non-procurement 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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During our testing of the Orange County Public Works (OCPW) and the County Executive Office?s (CEO) provisions for procurement requirements under the COVID-19 Coronavirus State and Local Fiscal Recovery Funds, we noted the following instances where there was no evidence that the OCPW or CEO departments verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract, in accordance with County policy ? Three (3) of three (3) contracts through the OCPW department selected for testing. ? Two (2) of six (6) contracts through the CEO department selected for testing. Cause: The OCPW, and CEO departments did not follow their policy to verify the information described in the condition prior to entering the transactions. Effect: The County?s control and compliance were not consistently followed, which required verification of suspension or debarment prior to entering the contract. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of eight (8) procurement contracts were sampled from OCPW and six (6) out of fourteen (14) procurement contracts were sampled from the CEO department for the COVID-19 Coronavirus State and Local Fiscal Recovery Funds. The condition above was identified during our testwork of the OCPW and CEO departments? internal controls over procurement and suspension and debarment. Repeat Finding from Prior Years: No. Recommendation: We recommend that the OCPW and CEO departments adhere to their procurement procedures requiring the suspension or debarment verification is performed prior to entering into a covered transaction. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Compliance Requirements: Procurement Type of Finding: Significant Deficiency in Internal Control and Instance of Noncompliance Criteria: 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and four (4) out of six (6) contracts selected for testing within the CEO department: ? Byrd Anti-Lobbying Amendment The following information was not provided at the time of the contract award for three (3) of three (3) contracts selected for testing within the OCPW department and three (3) out of six (6) contracts selected for testing within the CEO department: ? Clean Air Act and Federal Water Pollution Control Act provision Cause: The OCPW and CEO departments? procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The OCPW and CEO departments did not identify the applicable required provisions of the contract to the contractors at the time of the contract award. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: The entire population of three (3) contracts were selected for procurement and suspension and debarment testing for the OCPW department. A nonstatistical sample of six (6) out of fourteen (14) contracts were selected for procurement and suspension and debarment testing for the CEO department. Repeat Finding from Prior Years: No. Recommendation: We recommend the OCPW and CEO departments modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.