Criteria or specified requirement (including statutory, regulatory, or other citation: 2 CFR section 200.303 of the Uniform Guidance requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. The 2 CFR section 200.303 indicates that the internal controls required to be established by a non-federal entity receiving federal awards should be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. 2 CFR section 200.403 states the following: “Costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles; (b) conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items; (c) be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity; (d) be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost; (e) be determined in accordance with generally accepted accounting principles; (f) not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period; (g) be adequately documented; and (h) cost must be incurred during the approved budget period.” Condition: The New York and Presbyterian Hospital (the Hospital) has processes and internal controls in place to ensure costs submitted to the Federal Emergency Management Agency (“FEMA”) in relation to the Disaster Grants – Public Assistance program were eligible under FEMA’s provisions and were allowable COVID-19-related expenses. These internal controls include ensuring completeness and accuracy of the costs to ensure the costs comply with the terms and conditions of the award. The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. Cause: The Hospital’s internal controls did not identify that management inadvertently included certain costs in the FEMA reimbursement submission that were based on the invoiced amounts from a specific vendor that differed from the actual amounts paid by the Hospital. The difference was due to payment discount provisions utilized in accordance with a previously existing vendor agreement for one specific vendor, resulting in an overstatement of amounts included in the FEMA reimbursement request submitted in the Grants Portal. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. Effect or potential effect: Due to the above, there is a misstatement of the amounts reported in the FEMA reimbursement submission in the Grants Portal resulting in questioned costs of approximately $268,900. Questioned costs: Approximately $268,900, representing the difference between the amounts paid for certain invoices as compared to the amounts incorrectly submitted in the Grants Portal and certain duplicated items. Context: During our testing of FEMA expenditures underlying the grant for FEMA project number 140215, we identified expenditures that were paid at discounted amounts (in accordance with payment terms with a specific vendor) but included in the FEMA reimbursement submission in the Grants Portal at the full invoice amount, without consideration to the discount taken. The invoiced amounts exceeded the actual amounts paid by approximately $84,500. The terms and conditions of the FEMA award require recipients to submit eligible costs incurred limited to the amount paid, thus this issue results in questioned costs. Additionally, through the Uniform Guidance audit procedures and management’s further review of submitted costs, duplicated items totaling approximately $184,400 were identified within the population of submitted costs. The total FEMA expenditures for project number 140215 included on the Hospital’s schedule of expenditures of federal awards is $174.1 million, which includes $16.9 million related to the specific vendor for the payment-related issue described above. The FEMA-obligated amount under this grant is the third obligation for costs that the Hospital submitted to FEMA for reimbursement under this project. The project was initially established through FEMA’s optional expedited funding application and subsequently amended to a streamlined project under FEMA’s provisions; the amendment also extended the grant period beyond the initial ninety-day period of the original application to cover the period through July 1, 2022. The Hospital has adjusted for a portion of the questioned costs in a subsequent claim submission and management has indicated that they will follow this same process for the balance of the questioned cost items. Additionally, management anticipates that any reimbursement revisions, such as for the questioned costs described above, identified related to the third obligated amount will be addressed through the reconciliation of the overall project cost, inclusive of expected payments to the Hospital for additional eligible costs that have been submitted by the Hospital. Identification as a repeat finding, if applicable: The finding is not a repeat finding. Recommendation: Management should correct the cost summary schedule for this project during the reconciliation of the overall project cost, or address in another manner as directed by FEMA. Additionally, management should continue to review on an ongoing basis for similar costs included in the FEMA reimbursement submission for potential submission errors related to discounted amounts. View of responsible officials: Management agrees with the finding.
Criteria Per 2 CFR § 200.303, non-Federal entities are required to establish and maintain effective internal control over federal awards 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 Our internal control testing revealed one instance in which the voucher package for one cash disbursement in the amount of $530,096 did not include documented review and approval by management prior to issuance of payment to the vendor. Effect Without proper review and approval by management prior to issuance of payment to vendors, the Corporation cannot provide reasonable assurance that the federal award has been managed in compliance with all applicable Federal statutes, regulations, and the terms and conditions of the federal award.
FINDING 2023-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act for the purpose of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. The Health Issues and Challenges grant is a reimbursable grant, whereby the County received reimbursement on a per-case basis at a stated rate for Case Management and Environmental Investigation activities performed. The County Department of Health received federal receipts related to the grant in the amount of $130,479 during 2023. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. Receipts of the program were adequately identified through the use of an account number within the County Health Fund (285) in the County's ledger (ledger) which was unique to the Health Issues and Challenges grant receipts. However, the ledger did not adequately identify the expenditures of the grant program within the County Health Fund. Through inquiry with the County Department of Health employees and review of unit-prepared support of grant expenditures, we determined expenditures were made with grant funds during the audit period; however, we were unable to distinguish between the expenditures of the Health Issues and Challenges grant and all other activities of the County Department of Health in the County Health fund. Due to the lack of separate identification of expenditures in the financial records, we were not able to establish a population from which to audit the Health Issues and Challenges grant for compliance with the following compliance requirements of the program: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment As such, the full award amount of $130,479, as reported on the Schedule of Expenditures of Federal Awards, was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.300(b) states in part: "The non-Federal entity is responsible for complying with all requirements of the Federal award. . . ." 2 CFR 200.302 states in part: "(a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. . . . (b) The financial management system of each non-Federal entity must provide for the following . . . (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the Assistance Listings title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any. (2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in §§ 200.328 and 200.329. . . . (3) Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, financial obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. (4) Effective control over, and accountability for, all funds, property, and other assets. . . ." Cause The County Department of Health was unable to differentiate expenditures made from federal and non-federal funds within its ledger for the Heath Issues and Challenges grant. Effect Without the proper implementation of an effectively designed system of internal controls, a population of expenditures associated with the Health Issues and Challenges grant could not be determined. As such, the County Department of Health cannot ensure nor can we determine that expenditures of the grant were not unallowable, within the proper period, and adhered to established practices and policies. Questioned Costs We identified $130,479 in known questioned costs as noted in the Condition and Context. Recommendation We recommended that management of the County Department of Health establish a system of internal controls to ensure that grant award funds are adequately accounted for and tracked in such a manner as to determine the activity, receipts, and disbursements associated with the grant. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): PO 20011717 Pass-Through Entity: Indiana State Department of Health Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context The County Department of Health, a department within the County, was awarded the Health Issues and Challenges grant through the Indiana State Department of Health financed through the American Rescue Plan Act (ARPA) for the purposes of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. As part of sound management of the federal award, the County Department of Health was responsible for implementing a system of internal controls that would ensure compliance with the applicable requirements. The County Department of Health did not properly design or implement such a system. The County Department of Health was required to submit data through the online portal, National Electronic Disease Surveillance System (NEDSS) Base System (NBS), monthly beginning in October 2022. The submitted data included program specific metrics relating to patient case management of certified Elevated Blood Lead Levels (EBLLs). The County Department of Health was also required to ensure environmental investigation activities completed, including risk assessments and environmental inspections, were documented in the Indiana I-LEAD database monthly by a licensed Lead Risk Assessor. Environmental investigation activities performed by the County Department of Health were documented in the Indiana I-LEAD database by a licensed Lead Risk Assessor who was an employee of the County Department of Health. Similarly, case management activities performed were documented in the NEDSS Base System (NBS). Once activities were documented in the Indiana I-LEAD database and NBS systems, the activities were further documented in a spreadsheet by the Lead Risk Assessor (for I-LEAD activities) and the Case Management Coordinator (for NBS activities). The spreadsheet was reviewed by the Director of the Environmental Services Division and the Finance Director monthly. The Finance Director then used the spreadsheet to prepare the monthly reimbursement requests and sent the monthly reimbursement requests to the Indiana State Department of Health. We determined through inquiry with the Director of the Environmental Services Division and the Finance Director that while there was a review of the monthly spreadsheet, there was not a second review of the spreadsheet back to the activities reported in the Indiana I-LEAD database and NBS for accuracy. Additionally, the Finance Director prepared and submitted the reimbursement requests to the State without a second review or oversight process in place to prevent, or detect and correct, errors prior to submission. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls, which would include segregation of key functions, was not designed by management of the County Department of Health to ensure the state was provided with complete and accurate information related to the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds award. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect management's statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of a system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County Department of Health design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reports are complete and accurate. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context Recipients of COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) awards are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon the type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. Counties with a population that exceeds 250,000 residents are further required to submit annually a Recovery Plan Performance Report (RPPR). The RPPR provides the public and the Treasury with both retrospective and prospective information on the projects that recipients are undertaking or planning to undertake with program funding and how they are planning to ensure program outcomes are achieved in an effective, efficient, and equitable manner. The County was classified as a metropolitan county with a population that exceeds 250,000 residents. As such, quarterly P&E reports were to cover one calendar quarter and were to be submitted to the Treasury by the last day of the month following the end of the period covered. The annual RPPR was to be submitted to the Treasury by July 31, 2023. An employee of the Board of County Commissioners prepared and submitted the four required quarterly P&E reports during the audit period; however, there was no review or oversight process in place to prevent, or detect and correct, errors. Additionally, an employee of the Board of County Commissioners submitted the required annual RPPR during the audit period, which was compiled by a contracted vendor on the County's behalf. The vendor worked with the employee to get the necessary information to complete the report. Once complete, the report was provided to the employee, who then submitted the report without a review or oversight process in place to prevent, or detect and correct, errors. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause A proper system of internal controls, which would include segregation of duties, over SLFRF reporting was not designed by the Board of County Commissioners in order to prevent, detect or correct, material noncompliance. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect management's statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper design or implementation of the components of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Board of County Commissioners design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County received a total COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation of $73,674,384 and chose to calculate its own revenue loss allowance, which totaled $35,932,557, to use for government services. Some SLFRF program funds expended in 2023 were expended under the revenue loss eligible use category. Additional program funds expended in 2023 were expended under the other eligible use categories. Procurement Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is set at $250,000 unless a lower, more restrictive threshold is set by a non-federal entity. As Indiana Code has set a more restrictive threshold of $150,000, informal procurement methods are permitted when the value of the procurement does not exceed $150,000. This informal process allows for methods other than the formal bid process. The informal process is divided between two methods based on thresholds. Micro-purchases, typically for those purchases $10,000 or under, and small purchase procedures for those purchases above the micro-purchase threshold, but below the simplified acquisition threshold. Micro-purchases may be awarded without soliciting competitive price rate quotations. If small purchase procedures are used, then price or rate quotations must be obtained from an adequate number of qualified sources. For funds expended under the revenue loss eligible use category, the above listed procurement requirements do not apply. During the audit period, the County had four vendors with purchases over the $10,000 micropurchase threshold which were expended under an eligible use category other than revenue loss and, as such, were considered small purchase procurements. The County did not provide competitive price quotations for the small purchase procurements for three of the four vendors, which totaled $257,038. Suspension and Debarment Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. During the engagement, an employee of the Board of County Commissioners stated that verification was completed by checking the Excluded Parties List System when covered transactions were entered into by the County to verify that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Six covered transactions, totaling $3,952,203, were paid from SLFRF funds to six different vendors for goods or services that equaled or exceeded $25,000 during the audit period. Three of the six covered transactions were selected for testing. For all three transactions tested, documentation was not provided that the vendor's suspension and debarment status was verified. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. (a) Informal procurement methods. When the value of the procurement for property or services under a Federal award does not exceed the simplified acquisition threshold (SAT), as defined in § 200.1, or a lower threshold established by a non-Federal entity, formal procurement methods are not required. The non-Federal entity may use informal procurement methods to expedite the completion of its transactions and minimize the associated administrative burden and cost. The informal methods used for procurement of property or services at or below the SAT include: . . . (2) Small purchases — (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. . . . Cause The County was unable to provide documentation to demonstrate it had properly procured services. In addition, the County was unable to provide documentation to demonstrate it had checked the Excluded Parties List System, per the County's procedures, to ensure vendors were not suspended or debarred prior to entering into covered transactions that exceeded $25,000. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot demonstrate it obtained an adequate number of price or rate quotations prior to selecting a vendor. Therefore, the County could have overpaid for the services obtained. Furthermore, without the proper implementation of an effectively designed system of internal controls, the County cannot ensure the vendors paid with federal funds are eligible to participate in federal programs. Any program funds the County used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the Board of County Commissioners strengthen the County's system of internal controls to ensure that an adequate number of price or rate quotations are obtained for small purchase procurements. Additionally, we recommended policies and procedures be strengthened to ensure appropriate supporting documentation for federal programs is retained. Lastly, we recommended that the Board of County Commissioners strengthen the County's system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-002. Condition and Context Procurement Policy Recipients may use award funds to enter into contracts to procure goods and services necessary to implement one or more of the eligible purposes outlined for COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) award funds. Policies and procedures for the procurement of the goods and services must be the County's own documented procedures which reflect applicable state and federal laws and regulations. INDIANA STATE BOARD OF ACCOUNTS 18 BARTHOLOMEW COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The County did not have documented procurement procedures or policies reflecting applicable state or federal laws and regulations for procuring goods and services paid with federal funds. Suspension and Debarment Prior to entering into subawards and covered transactions with the SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County did not have any policies or procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded. A population of seven covered transactions, totaling $2,631,684, that equaled or exceeded $25,000 paid from SLFRF funds were identified. Four of the seven covered transactions, totaling $1,399,462, were selected for testing. For each of the four transactions, the County did not verify the vendors' suspension or debarment status prior to payment due to the County not having any policies or procedures in place to verify that contractors were neither suspended nor debarred, or otherwise excluded or disqualified, from participating in federal assistance programs or activities. The lack of intenral controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: INDIANA STATE BOARD OF ACCOUNTS 19 BARTHOLOMEW COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The County did not have a procurement policy in place that contained the requirements of the procurement standards as outlined in the Code of Federal Regulations. Due to the timing of the adoption of the County's Suspension and Debarment Policy, which defines procedures to verify suspension and debarment status for covered transactions, the items selected for testing were not verified. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure that goods and services are appropriately procured and that contractors paid with federal funds are eligible to participate in federal programs. Any program funds the County used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommend that management of the County strengthen its system of internal controls to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into contracts. We also recommended strengthening its policies to reflect applicable state and federal laws and regulations for procuring goods and services paid with federal funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 2023 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters INDIANA STATE BOARD OF ACCOUNTS 20 BARTHOLOMEW COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-003. Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation of more than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) award funds. As such, the initial P&E report, covering the period from March 3, 2021 to December 31, 2021, was required to be submitted to the Treasury by January 31, 2022. The subsequent quarterly reports were to cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. The County submitted all four P&E reports that were required during the audit period. Although a review process over the reports was in place, the internal controls were not effective and did not detect and allow corrections of errors in the reports. As a result, the following errors were noted: The current period expenditures were incorrectly reported on two of four reports. The current period expenditures were underreported by $70,309 and $13,090 in the Q4 2022 and Q3 2023 reports, respectively. The total cumulative expenditures were incorrectly reported on all four reports. The total cumulative expenditures were overreported by $174,750 in the Q4 2022 and Q1 2023 reports, and $19,204 in the Q3 2023 report. The total cumulative expenditures were underreported by $690,272 in the Q2 2023 report. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 21 BARTHOLOMEW COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, . . ." Cause A proper system of internal controls was not designed or implemented by management of the County to prevent and detect errors on the P&E report prior to submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, the County did not report current period expenditures and total cumulative expenditures properly when filing the P&E reports for the quarterly reporting periods from October 1, 2022 to September 30, 2023. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. In addition, not meeting the SLFRF reporting requirements increases the likelihood that the public and the Treasury will not have access to transparent and accurate information regarding expenditures of federal awards. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County develop policies and procedures to ensure the County provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Repeat Finding This is a repeat finding from the immediately prior audit report. The prior audit finding number was 2022-004. INDIANA STATE BOARD OF ACCOUNTS 17 WHITE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Prior to entering into subawards and covered transactions with COVID-19 - Coronavirus State and Local Fiscal Recovery Funds award funds, recipients are required to verify that vendors are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County's procedure to ensure vendors were not suspended or debarred was to add a clause to contracts for the vendor to certify they were not suspended or debarred. A population of five covered transactions was identified. Two covered transactions, totaling $1,710,669, were selected for testing. For both covered transactions tested, the contract utilized did not include a clause for suspension and debarment. No other procedures were performed for the two transactions, thus documentation to show that suspension and debarment was verified prior to entering into a covered transaction was not provided. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The County's system of internal controls as established by management did not take into account situations in which the County's contract template is not utilized or a formal contract is not required. INDIANA STATE BOARD OF ACCOUNTS 18 WHITE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect The County's contract template was not utilized, and, therefore, the necessary suspension and debarment clause was not included. Any program funds the County used to pay contractors that have been suspended or debarred would be unallowable and the funding agency could potentially recover funds. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County strengthen their policies and procedures to include situations when their contract template is not utilized, or when a formal contract is not necessary so as to ensure that contractors paid $25,000 or more, all or in part with federal funds, are not suspended, debarred, or otherwise excluded prior to making payment or entering into a contract. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2023 Compliance Requirement: Reporting Audit Finding: Material Weakness Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a county with a population below 250,000 residents that received an allocation of less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. As such, the P&E report covering the period from April 1, 2022 to March 31, 2023, was required to be submitted to the Treasury by April 30, 2023. The P&E report was submitted in April 2023, as required; however, there were no internal controls in place that would likely be effective in preventing, or detecting and correcting, noncompliance related to the P&E report. One employee prepared and submitted the report without evidence of an oversight or review process. The lack of internal controls was systemic issue throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 19 WHITE COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause The County did not implement a system of internal controls over reporting. Effect Without the proper implementation of an effectively designed system of internal controls, errors could occur and remain undetected. As such, the County cannot ensure that the reports submitted are materially accurate and correct. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County design and implement a proper system of internal controls, including policies and procedures to ensure that the County provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
Federal Award Allowable Activities and Cost Requirements Payroll Approval Federal Awarding Agency - Department of Health and Human Services Assistance Listing Number - 93.044, 93.045, 93.053, 93.052 Federal Awarding Agency - Department of Veteran Affairs Assistance Listing Number - 64.044 Questionned Costs - None Criteria: 2 CFR Part 200 in general and 2 CFR section 200.303(a) require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs and cost principles. 2 CFR section 200.430(i)(1) requires that charges to Federal awards or salaries and wages must be based on records that accurately reflect the work performed. The records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) And be incorporated into the official records of the non-Federal entity. Condition: We identified two pay periods in our testing where internal controls related to review of the payroll reports did not have evidence of all required approvals necessary to ensure compliance with allowable costs and cost principles before funds were disbursed or such approvals were not able to be located. Cause: Evidence of review over two payroll reports selected for testing were not able to be located due to transition in CFO position during the year. Effect: Allowable costs and cost principles compliance requirements may not be met due to lack of evidence of internal controls. Recommendation: We recommend that the review of all payroll reports be documented and maintained to ensure costs are allowable before they are disbursed.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2022 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based on the type of recipient and the recipient's population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation of less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds. As such, the initial P&E report, covering the period from March 3, 2021 to March 31, 2022, was required to be submitted to the Treasury by April 30, 2022. The subsequent annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. INDIANA STATE BOARD OF ACCOUNTS 18 CLINTON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) The County submitted one P&E report during the audit period, which was obtained from the Treasury's website. Although one employee prepared the P&E report and another reviewed the entries, the system of internal controls was not effective in preventing, detecting, or correcting errors. The data submitted included amounts which should not have been included and amounts which were not supported by the County's records. Errors identified included the following: Total Cumulative Obligations were overstated by $907,630. Total Cumulative Expenditures were overstated by $4,332,524. The lack of effective internal controls and noncompliance were isolated to the P&E report submitted during the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, . . ." Cause Although a system of internal controls over the P&E report was designed by management, which included segregation of duties, it did not ensure that the County provided the Treasury with complete and accurate information related to the SLFRF awards. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. INDIANA STATE BOARD OF ACCOUNTS 19 CLINTON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. In addition, not meeting the SLFRF reporting requirements, by reporting erroneous data, increases the likelihood that the public and the Treasury will not have access to transparent and accurate information regarding expenditures of federal awards. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County design and implement a proper system of internal controls that would ensure appropriate reviews, approvals and oversight are taking place. Additionally, management should develop policies and procedures to ensure that the County provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY2022 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing it to claim its total COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation of $6,293,126 as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships as there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. INDIANA STATE BOARD OF ACCOUNTS 20 CLINTON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Prior to entering into subawards and covered transactions with federal award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods or services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. Verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. Covered transactions in the amount of $1,730,492 were made during the audit period to three vendors. Of the three vendors used by the County, one vendor contract included a suspension and debarment clause. However, for the two remaining vendors, the County did not check the ELPS, nor was a certification collected from the vendors, nor was a clause in the agreements. Although the County had a policy to include a clause in vendor contracts related to covered transactions, the County did not have effective internal controls to ensure that the suspension and debarment clause was added to all the contracts. The lack of effective internal controls and noncompliance were isolated to the two vendors noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The system of internal controls established by management of the County was not properly implemented to ensure that the policies and procedures in place related to suspension and debarment resulted in adequate supporting documentation being retained for audit. INDIANA STATE BOARD OF ACCOUNTS 21 CLINTON COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system is incapable of effectively preventing, or detecting and correcting, material noncompliance. As a result, no documentation was available for the status of two vendors to whom payment equal to or in excess of $25,000 was paid. Any program funds the County used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management strengthen its system of internal controls to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any contracts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2023-002 – Approval of Expenditures Federal Agency: U.S. Department of the Interior; U.S. Fish & Wildlife Service Federal program title: Endangered Species Conservation Recovery Implementation Funds Assistance Listing Number: 15.657 Award Period: 09/30/2020 – 09/30/2026 Type of Finding: Compliance and significant deficiency in internal control over compliance and Federal Agency: National Science Foundation Federal program title: Research and Mentoring for Postbaccalaureates in Biological Sciences Assistance Listing Number: 47.074 Award Period: 04/01/2022 – 09/30/2026 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award. Condition: During our review of charges to federal programs, many charges were incurred on employees’ credit cards. While most credit statements and related receipts and invoices are reviewed by either the Vice President of Conservation and Research or the Director of Applied Conservation, we noted instances of no employee reviewing the Vice President of Conservation and Research, the Director of Applied Conservation, or certain department heads’ credit card charges. Questioned Costs: None noted. Context: Endangered Species Conservation Recovery Implementation Funds: We noted nine instances from the sample of fifty-three credit charges that did not have documentation of proper approval. Research and Mentoring for Postbaccalaureates in Biological Sciences: We noted one instance from the sample of twenty-two credit charges that did not have documentation of proper approval. Cause: There was no evidence of the Garden’s formal process of ensuring all expenditures are appropriated documented and approved. Effect: For transactions related to federal grants, without the appropriate supporting documentation, charges may be disallowed. Recommendation: We recommend that management establish controls and implement policies to ensure that support is obtained and maintained for all expense transactions. Management’s Response: Refer to the Correction Action Plan.
2023-002 – Approval of Expenditures Federal Agency: U.S. Department of the Interior; U.S. Fish & Wildlife Service Federal program title: Endangered Species Conservation Recovery Implementation Funds Assistance Listing Number: 15.657 Award Period: 09/30/2020 – 09/30/2026 Type of Finding: Compliance and significant deficiency in internal control over compliance and Federal Agency: National Science Foundation Federal program title: Research and Mentoring for Postbaccalaureates in Biological Sciences Assistance Listing Number: 47.074 Award Period: 04/01/2022 – 09/30/2026 Type of Finding: Compliance and significant deficiency in internal control over compliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statues, regulations, and conditions of the federal award. Condition: During our review of charges to federal programs, many charges were incurred on employees’ credit cards. While most credit statements and related receipts and invoices are reviewed by either the Vice President of Conservation and Research or the Director of Applied Conservation, we noted instances of no employee reviewing the Vice President of Conservation and Research, the Director of Applied Conservation, or certain department heads’ credit card charges. Questioned Costs: None noted. Context: Endangered Species Conservation Recovery Implementation Funds: We noted nine instances from the sample of fifty-three credit charges that did not have documentation of proper approval. Research and Mentoring for Postbaccalaureates in Biological Sciences: We noted one instance from the sample of twenty-two credit charges that did not have documentation of proper approval. Cause: There was no evidence of the Garden’s formal process of ensuring all expenditures are appropriated documented and approved. Effect: For transactions related to federal grants, without the appropriate supporting documentation, charges may be disallowed. Recommendation: We recommend that management establish controls and implement policies to ensure that support is obtained and maintained for all expense transactions. Management’s Response: Refer to the Correction Action Plan.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Allowable Costs/Cost Principles Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): YR 2023 Compliance Requirements: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing it to claim its total COVID-19 - Coronavirus State and Local Fiscal Recovery Fund (SLFRF) allocation of $4,014,711 as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category and that recipients' use of revenue loss funds would not give rise to subrecipient relationships as there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. INDIANA STATE BOARD OF ACCOUNTS 17 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) On May 11, 2021, the Board of County Commissioners passed Ordinance 2021-07 that created a new fund and adopted the American Rescue Plan (ARP). The Ordinance included the procedures for spending the ARP funding which included the following: The Board of County Commissioners will establish the plan, conditions, and rules upon which the funds are to be requested and used. Funds shall be appropriated by the County's fiscal body before use. All expenditure of funds shall be approved by the Board of County Commissioners with any and all claims to be paid from the County's ARP fund. The County Council approved appropriations for all eleven expenditures from the ARP fund in 2023. All eleven expenditures were tested for compliance with the Allowable Costs/Cost Principles compliance requirement. Two of the eleven expenditures, totaling $44,500, did not have adequate supporting documentation to determine the allowability of the cost. In addition, the County did not have written procedures for determining the allowability of costs in accordance with subpart E of 2 CFR 200. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. . . . (g) Be adequately documented. . . ." 2 CFR 200.302(b)states: "The financial management system of each non-Federal entity must provide for the following . . . (7) Written procedures for determining the allowability of costs in accordance with subpart E of this part and the terms and conditions of the Federal award." INDIANA STATE BOARD OF ACCOUNTS 18 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The lack of internal controls allowed for the County to charge questionable expenditures to the SLFRF program that could be requested to be returned by the Treasury. The County also did not adopt the required written procedures for determining allowability of costs for federal awards. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, costs that were not adequately documented were paid for with federal funds. Questioned Costs Known questioned costs of $44,500 were identified as detailed in the Condition and Context. Recommendation We recommend the County's management establish a proper system of internal controls and develop policies and procedures to ensure costs are allowable for SLFRF award funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): SWIF221677 Pass-Through Entity: Indiana Finance Authority Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context Procurement - Policy The County had not established a purchasing policy that would reflect applicable state laws and regulations, including procedures to avoid the acquisition of unnecessary or duplicative items; procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured; and did not maintain written standards of conduct covering conflicts of interest and governing actions of its employees engaged in the selection, award, and administration of contracts. INDIANA STATE BOARD OF ACCOUNTS 19 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Procurement and Suspension and Debarment The County entered into an interlocal agreement with the City to procure services for a Sewer Lift Station Improvement/Line Extension to the New County Jail project. Per the agreement, the City would be responsible for all the procurement and suspension and debarment processes involved in the project, and the County would be responsible for the compliance with all grant funding for the project. On September 23, 2021, the County received notification that it was eligible to receive $1,900,000 from the Indiana Finance Authority (IFA) for a SWIF grant from SLFRF funds with the intention of using the funding for the Sewer project shared by the County and City. The notification stated that co-funding would be provided by the County and that the County could enter into the SWIF grant agreement with the IFA once the funding was secure. On February 24, 2022, the City's Common Council approved a bid with B & T Drainage for the project. On March 6, 2022, the County Council approved a $2,330,000 appropriation from its SLFRF funds for co-financing of the project and, on the same day, signed a grant agreement with the IFA for the SWIF grant funded with SLFRF funds totaling $2,300,000. The project was completed as of December 31, 2023. The County did not provide any of the following documentation requested to verify compliance with the procurement and suspension and debarment requirements for the SWIF funds spent on the project: Copy of the original contract for $3,965,507. Copy of any change orders. Copy of the Board minutes where the bid was awarded by the Common Council. Copy of the original bids made on the project. Copy of documentation that vendor was not suspended or debarred. The lack of internal controls and lack of appropriate supporting documentation was isolated to the project noted above. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 20 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (c) (1) The non-Federal entity must maintain written standards of conduct covering conflicts of interest and governing the actions of its employees engaged in the selection, award and administration of contracts. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of the contract type, contractor selection of rejection, and the basis for the contract price. . . ." 2 CFR 200.320 states in part: "The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. . . . (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. (i) In order for sealed bidding to be feasible, the following conditions should be present: (A) A complete, adequate, and realistic specification or purchase description is available; (B) Two or more responsible bidders are willing and able to compete effectively for the business; and (C) The procurement lends itself to a firm fixed price contract and the selection of the successful bidder can be made principally on the basis of price. INDIANA STATE BOARD OF ACCOUNTS 21 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (ii) If sealed bids are used, the following requirements apply: (A) Bids must be solicited from an adequate number of qualified sources, providing them sufficient response time prior to the date set for opening the bids, for local, and tribal governments, the invitation for bids must be publicly advertised; (B) The invitation for bids, which will include any specifications and pertinent attachments, must define the items or services in order for the bidder to properly respond; (C) All bids will be opened at the time and place prescribed in the invitation for bids, and for local and tribal governments, the bids must be opened publicly; (D) A firm fixed price contract award will be made in writing to the lowest responsive and responsible bidder. Where specified in bidding documents, factors such as discounts, transportation cost, and life cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of; and (E) Any or all bids may be rejected if there is a sound documented reason. . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The County participated in a joint project with the City in which the City handled the procurement process. As the County was ultimately responsible for compliance, copies of the quotes or bids obtained by the City should have been obtained by the County; however, this documentation was not obtained or provided for audit. In addition, documentation to demonstrate the City checked the vendor was not suspended or debarred prior to entering into the contract should have been obtained by County. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure that the services obtained provided full and open competition or the basis of the price. In addition, the County cannot ensure the vendors paid were eligible to participate in federal programs. Any program funds the County used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. INDIANA STATE BOARD OF ACCOUNTS 22 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Noncompliance with the provisions of federal regulations and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended the County establish documented procurement procedures consistent with state and local laws for the acquisition of property or services required under a federal award or subaward as outlined in the code of federal regulations. We also recommended the County adhere to the procurement and suspension and debarment requirements and obtain required bids and verify that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any covered transactions. Finally, we recommended the County obtain and retain appropriate documentation for all expenses paid with SLFRF funds. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-005 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): YR 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing it to claim its total COVID-19 - Coronavirus State and Local Recovery Funds (SLFRF) allocation of $4,014,711 as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category and that recipients' use of revenue loss funds would not give rise to subrecipient relationships as there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contracts and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under procurement and nonprocurement transactions (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the County was only required to comply with suspension and debarment requirements related to covered transactions. INDIANA STATE BOARD OF ACCOUNTS 23 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Upon inquiry of the County to determine its policies and procedures related to suspension and debarment requirements, the County stated that they did not have policies or procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Covered transactions paid to seven different vendors, totaling $403,071, for goods or services that equaled or exceeded $25,000 that were paid from ARP funds were identified and tested. After examination, the County had not verified the vendor's suspension and debarment status for any of the seven vendors prior to issuing payment. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The County had not established a system of internal controls for suspension and debarment. The County did not verify any covered transactions identified in testing that they were not suspended or debarred prior to entering into the covered transaction. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure the vendors paid with federal funds are eligible to participate in federal programs. Any program funds the County used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the County. INDIANA STATE BOARD OF ACCOUNTS 24 SULLIVAN COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure contractors, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering into any contracts with those vendors. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Period of Performance Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Period of Performance Audit Findings: Material Weakness, Modified Opinion Condition and Context On December 15, 2020, the City entered into a Lease-Purchase agreement with the Crossroads Bank for police and fire radios. On August 28, 2023, the City made a payment of $2,431,243 to the Crossroads Bank to pay the remaining balance due for the police and fire radios from its Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation. Per SLFRF program regulations, the period of performance for the SLFRF award began on March 3, 2021, when the funds were disbursed by the grantor agency. All costs must be incurred by December 31, 2024, and funds must be liquidated before December 31, 2026. Although the City's purchase is an eligible purchase under the SLFRF Final Rule, the purchase was initiated and approved by the City prior to the SLFRF period of performance beginning date of March 3, 2021. Further, the project was not prospective in nature, and the City incurred a financial obligation prior to the beginning of the period of performance. As such, the payment of $2,431,243 was determined to be questioned costs. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 35.5(a) states: "In general. A recipient may only use funds for the purposes enumerated in § 35.6 (b) through (f) to cover costs incurred during the period beginning March 3, 2021, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2) and 603(c)(2) of the Social Security Act, as applicable. A recipient may only use funds for the purposes enumerated in § 35.6 (g) through (h) to cover costs incurred during the period beginning December 29, 2022, and ending December 31, 2024, subject to the restrictions set forth in sections 602(c)(2), 602(c)(5)(C), 603(c)(2), and 603(c)(6)(B) of the Social Security Act, as applicable." 31 CFR 35.3 states in part: ". . . Obligation means an order placed for property and services and entering into contracts, subawards, and similar transactions that require payment. . . ." 2 CFR 200.403 states in part: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: . . . (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3)." Cause Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these polices. The system of internal controls, as designed and implemented by management of the City, was not effective to ensure SLFRF funds were used appropriately. The original date of the contract was not considered when determining the funding source of the payment. Effect Without the proper implementation of an effectively designed system of internal controls, a payment on a debt associated with a project outside of the period of performance occurred. Noncompliance with the provisions of federal statutes, regulations, and terms and conditions of the federal award could result in the loss of future federal funding to the City. Questioned Costs Known questioned costs in the amount of $2,431,243 were identified as noted in the Condition and Context. Recommendation We recommended that management of the City establish a system of internal controls and develop policies and procedures to ensure SLFRF funds are used appropriately. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): CY 2023 Compliance Requirement: Reporting Audit Findings: Material Weakness, Modified Opinion Condition and Context Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a metropolitan city with a population below 250,000 residents that was allocated more than $10 million in Coronavirus State and Local Fiscal Recovery Funds. As such, the P&E quarterly reports were to cover one calendar quarter and must be submitted to the Treasury by the last day of the month following the end of the period covered. The City submitted the required P&E reports during the audit period; however, a single employee prepared and submitted the reports without evidence of a review or oversight process in place to prevent, or detect and correct, errors. Due to the lack of internal controls, the P&E reports were not supported by the City's ledger. The following errors were identified: Quarter 1 2023 (January 1, 2023 to March 31, 2023) Current period expenditures for Quarter 1 2023 were $79,169 per the City's ledger; however, the P&E report reported $0 for the quarter. As a result, the reported amounts for current period obligations and current period expenditures were incorrect. Quarter 2 2023 (April 1, 2023 to June 30, 2023) Current period expenditures for Quarter 2 2023, were $178,326 per the City's ledger; however, the P&E report reported $0 for the quarter. As a result, the reported amounts for current period obligations and current period expenditures were incorrect. In addition, as of June 30, 2023, the City's ledger reflected cumulative program expenses of $4,693,765; however, the P&E report for that period reported total expenditures of $4,644,475, resulting in a variance of $49,290. As a result, the reported amounts for cumulative obligations and cumulative expenditures were incorrect. Quarter 3 2023 (July 1, 2023 to September 30, 2023) As of September 30, 2023, the City's ledger reflected cumulative program expenses of $7,858,115; however, the P&E report for that period reported total expenditures of $10,244,475, resulting in a variance of $2,386,360. As a result, the reported amounts for cumulative obligations and cumulative expenditures were incorrect. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 4, states in part: ". . . 4. Reporting. States, territories, and freely associated states are required to submit Project and Expenditure Reports on a quarterly basis according to the due dates noted in Table 1. A Project and Expenditure Report must be completed for each Project included in an approved Program Plan, beginning after a Project has been selected and a subaward has been executed (if applicable). Project and Expenditure Reports will be due each quarter thereafter for the remainder of the period of performance to continue to collect performance data. Additionally, to provide public transparency, Treasury will seek information from Recipients regarding their plans and practices related to promoting on-time and on-budget delivery related to CPF Projects. Following the initial report, all Project and Expenditure Reports will cover one three-month period and must be submitted to Treasury within 30 calendar days after the end of each period, except for the final report, which is due 120 calendar days after the end of the period of performance 1. Treasury may provide additional closeout instructions prior to the end of the period of performance." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds. . ." Cause A proper system of internal controls over the P&E report was not designed by management of the City, which would include segregation of key functions, to ensure the City provided the Treasury with complete and accurate information related to the SLFRF awards. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system did not prevent or detect material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. In addition, not meeting the SLFRF reporting requirements increases the likelihood that the public will not have access to transparent and accurate information regarding expenditures of federal awards. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City design and implement a proper system of internal controls that would provide a segregation of duties for the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. Additionally, management should develop policies and procedures to ensure that the City provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Numbers): CY 2023 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The City calculated a revenue loss allowance and claimed a Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation of $11,564,216 as revenue loss to use for government services. All SLFRF program funds expended in 2023 were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury's determination that the revenue loss eligible use category does not give rise to subawards, the City was only required to comply with suspension and debarment requirements related to contracts. During the engagement, the City stated that certifications were collected when covered transactions were entered into by the City to verify that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. Nine covered transactions were paid from SLFRF funds to nine different vendors for goods or services that equaled or exceeded $25,000 during the audit period. Four of the nine covered transactions were selected for tested. For two of four transactions tested, the City had not verified the vendor's suspension and debarment status. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause The City was unable to provide documentation to demonstrate it had collected a certification, per its procedures, to ensure vendors were not suspended or debarred prior to entering into covered transactions that exceeded $25,000. Effect Without the proper implementation of an effectively designed system of internal controls, the City cannot ensure the vendors paid with federal funds are eligible to participate in federal programs. Any program funds the City used to pay vendors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Furthermore, noncompliance with the provisions of federal statutes, regulations, and the terms and conditions or the federal award could result in the loss of future federal funding to the City. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the City strengthen its system of internal controls to ensure that all vendors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into any covered transactions. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2023-001: Activities Allowed or Unallowed & Allowable Costs/Cost Principles - Material Weakness in Internal Control and Material Noncompliance Repeat of Prior Audit Finding 2022-001 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2023 Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR sections 200.405 and 200.403(g) require federal awards be expended only for allowable activities and be adequately documented, respectively. Condition/Context: The Corporation was unable to provide a signed contract, payment information, invoice or reconciliation to evidence allowability of the expenditures or documentation of review and approval for the following: • For 3 out of 80 selections, no evidence of approval of the invoice or approval of signed contract could be provided (control). • For 27 out of 80 selections, no evidence of signed contract or payment support could be provided (compliance). This was not a statistically valid sample. Questioned Costs: Questioned costs were approximately $24,563. Cause: The Corporation did not retain/could not retrieve the signed contract or any related support for the disbursements due to poor document retention and staffing turnover and did not follow its internal control procedures by including formal, written review of disbursement payments. Effect: The Corporation has not complied with the specific requirements for activities allowed or unallowed and allowable costs/cost principles as described in the Uniform Guidance. Unallowable costs may have been charged to the federal program. Recommendation: We recommend that the Corporation review its process and implement procedures that would allow management to properly maintain all required documentation on its federal expenditures. Views of Responsible Officials: Over the past year, the Corporation has made significant improvements, reducing the occurrence of these findings compared to 2022. To continue to improve on and address this, the Corporation implemented a new HR solution, Rippling, in 2024, which will ensure all future agreements and rate changes are properly tracked and documented. This system will enhance the Corporation's document retention process and ensure compliance with federal regulations moving forward.
2023-002: Subrecipient Monitoring - Significant Deficiency Internal Control and Compliance Repeat of Prior Audit Finding 2022-005 Federal Program: Trans-National Crime Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs Federal Assistance Listing Number: 19.705 Federal Award Year: December 31, 2023 Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.332 requires pass-through entities to monitor the subrecipient, including verifying that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's federal expenditures exceed the threshold. Condition/Context: For the selection of 2 subrecipients, the Corporation did not inquire of the subrecipients to confirm their applicability of an annual Uniform Guidance audit, nor does the Corporation request a copy of the Uniform Guidance audit report to be provided, when applicable. This was not a statistically valid sample. Questioned Costs: Not determinable. Cause: The Corporation's procedures did not include this process as part of its policies and procedures. As a result, the Corporation did not request for an affirmation or a copy of the Uniform Guidance audit to be provided. Consequently, the Corporation did not verify whether the Uniform Guidance audit was applicable to any of its subrecipients. Effect: The Corporation's control design and operation does not provide reasonable assurance that the Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance. Recommendation: We recommend that the Corporation appropriately monitor its subrecipients to ensure that they are being audited in accordance with the Uniform Guidance, when applicable. In the event that such subrecipients do not require a Uniform Guidance audit, the Corporation should obtain and retain supporting documentation such as an affirmation letter from the subrecipients. When a subrecipient is subject to the Uniform Guidance audit, the Corporation should obtain a copy of the related audit report and perform a review of such audit report and note any potential findings that could pertain to the funding that the Corporation provided to such subrecipient. In addition, the Corporation should consider checking the Federal Audit Clearinghouse website to verify if its subrecipients submitted the single audit reporting package in the year that the Corporation funded. View of Responsible Officials: The Corporation will implement a process to obtain single audit affirmation letters from subrecipients annually, if applicable, and confirm as per current understanding and discussions with subrecipients during the due diligence process that their funding from the United States federal government sources during the agreement period will not exceed $750,000 annually. These steps will ensure proper subrecipient monitoring in alignment with federal regulations.
FINDING 2023-001 Procurement, Suspension and Debarment (Repeat Finding 2022-001 and 2021-001) Federal Agency: Department of the Treasury Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Criteria: The Department of the Treasury’s Final Rule (Effective April 1, 2022) encouraged the use of internal Procurement Policies and Procedures when procuring products and/or services. The Department of the Treasury’s Compliance and Reporting Guidance report (Effective June 24, 2021 through April 30, 2025) required recipients (i.e., City of Evanston) to ensure any procurement using CSLFRF funds to be consistent with the procurement standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327 as applicable. Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Section 200.318 through Section 200.327. A. Section 200.320 identifies four methods of procurement to be followed, among the methods of procurement the below are three identified thresholds: (a) Informal – micro purchases (any amount up to $10,000) (b) Informal – small purchases ($10,000.01 to $249,999.99) (c) Formal – sealed bids ($250,000 and above) (d) Noncompetitive procurement B. The City of Evanston Purchasing Manual requires the collection of three written quotes for any purchase between $2,500 and $25,000 purchased with federal grant funds, a formal bid process (Bid, RFP, RFQ) for any purchase $25,000 or above purchased with federal grant funds, and a justification memo for a sole source purchase for any amount above $2,500 purchased with federal grant funds. C. The City of Evanston Purchasing Manual requires that for purchases above $2,500 but less than $10,000, approval signature must be obtained from the Department Director. All purchases above $10,000 require approval signature from the City Manager. Purchases above $25,000 must also be approved by the City Council. D. Per Title 2 CFR section 180.300, participant entering into a covered transaction must verify that the person with whom it intends to do business is not excluded or disqualified by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. E. Title 2 CFR section 200.303 states the following regarding internal control: “The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.” Condition/Context: 1. We tested two purchase orders totaling $208,832.12. Our procedures revealed the following: a. Dated documentation that demonstrates suspension and debarment searches were performed prior to entering into a covered transaction were not retained in the respective procurement files. b. Documentation supporting multiple source solicitations was not available. Cause: 1. At the time these services were procured, the City of Evanston’s procurement policies requiring suspension and debarment checks were not implemented. 2. The City of Evanston’s procurement policies in relation to single source do not meet federal requirements. Effect: City of Evanston was not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200 and the requirements outlined in the City of Evanston Purchasing Manual as it relates to purchases above $25,000. Additionally, the effect of noncompliance can result in questioned costs. Recommendation: We recommend that City of Evanston: a. Date or time stamp suspension and debarment searches when performed. b. Revise procurement policies to mirror federal guidelines and requirements in relation to single and sole source purchases. c. Communicate and re-enforce its procurement policies and procedures to ensure compliance with applicable requirements. d. Ensure all departments are following applicable procedure in a uniform manner. Views of Responsible Officials: The purchases in question were made in the Equipment Replacement Fund where debarment searches are not required. ARPA funds were transferred to the Equipment Replacement Fund after the vehicles were delivered. We supplied the list of exclusions issued by the Office of Inspector General, which, from a compliance standpoint, demonstrates that the vendors are not suspended or debarred before entering a covered transaction. The list covers a one-month window and does not provide an exact date for when the list is retrieved from the Office of Inspector General website. When performing debarment searches in SAM.gov, if a vendor opts not to register or does not complete full registration process, the search results will display no matches, rendering it inconclusive to determine their standing. To prevent any potential deficiencies in control procedures, we intend to adopt the supplementary risk-based assessments proposed by the firm.
FINDING 2023-002 Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2022 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The Non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, . . ." Condition: The City had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the Department of Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a metropolitan city with a population below 250,000 residents that received an allocation of less than $10 million in Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). As, annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. Cause: A proper system of internal controls over the P&E report was not designed by management of the City, which would include segregation of key functions to ensure the City provided the Treasury with complete and accurate information related to the CSLFRF awards. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Context: The City submitted one P&E report during the audit period; however, a single employee prepared and submitted the P&E report without a review or oversight process in place to prevent, or detect and correct errors. In addition, the P&E report was not properly supported by the City’s records. All but $100,000 of the expenditures were reported under the Eligible Use Category of “Administrative Expenses.” However, the City’s expenditures during the audit period consisted of assistance to business and households, sewer infrastructure, and tourism support, none of which qualified as Administrative Expenses. Furthermore, the City reported that it was electing to take the Revenue Loss Standard Allowance, but the amount reported as Revenue Loss was $0. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Identification as a repeat finding, if applicable: Yes. The finding appeared in the prior year report as Finding 2022-001. Recommendation: We recommended that management of the City design and implement a proper system of internal controls that would provide a segregation of duties for the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. Additionally, management should develop policies and procedures to ensure that the City provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
FINDING 2023-002 Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2022 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Material Weakness, Modified Opinion Criteria: 2 CFR 200.303 states in part: "The Non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." 31 CFR 35.4(c) states in part: "Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, . . ." Condition: The City had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the Department of Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a metropolitan city with a population below 250,000 residents that received an allocation of less than $10 million in Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). As, annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. Cause: A proper system of internal controls over the P&E report was not designed by management of the City, which would include segregation of key functions to ensure the City provided the Treasury with complete and accurate information related to the CSLFRF awards. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Context: The City submitted one P&E report during the audit period; however, a single employee prepared and submitted the P&E report without a review or oversight process in place to prevent, or detect and correct errors. In addition, the P&E report was not properly supported by the City’s records. All but $100,000 of the expenditures were reported under the Eligible Use Category of “Administrative Expenses.” However, the City’s expenditures during the audit period consisted of assistance to business and households, sewer infrastructure, and tourism support, none of which qualified as Administrative Expenses. Furthermore, the City reported that it was electing to take the Revenue Loss Standard Allowance, but the amount reported as Revenue Loss was $0. Effect: Without the proper implementation of an effectively designed system of internal controls, including policies and procedures that provide segregation of duties and additional oversight as needed, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. Identification as a repeat finding, if applicable: Yes. The finding appeared in the prior year report as Finding 2022-001. Recommendation: We recommended that management of the City design and implement a proper system of internal controls that would provide a segregation of duties for the preparation and review of federal reports to ensure appropriate reviews, approvals, and oversight are taking place. Additionally, management should develop policies and procedures to ensure that the City provides the Treasury with complete and accurate information for the P&E report. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has prepared a corrective action plan.
Eligibility Federal Agency: U.S. Department of Agriculture (USDA) Program: WIC Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) (ALN 10.557) Pass-through Entity: State of Minnesota, Department of Health Federal Assistance Identification Number or Pass-Through Number: 202MN004W1003, 192MN004W5003 Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that each 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." The County is responsible for the verification of an applicant’s categorical eligibility, identity, and residency as well as the performance of assessments of an applicant’s nutritional risk. In addition, the County is also responsible for the input of this information as well as income and family size into HuBERT, the State’s WIC Information System. Condition: While we were able to test manual compensating controls over eligibility determination, we were not able to review and test the automated application controls and the related information technology general controls (ITGCs) within the HuBERT system, a state system that is administered by the state and required to be used by the County for eligibility determination, to determine whether controls are adequately designed and implemented and operating effectively. Cause: The State was not able to provide information regarding the design and effectiveness of HuBERT system controls nor were we able to test those controls directly due to complexities of data privacy and resources within the State. Effect: Although not found during our testing, benefits disbursed to participants in the program and issued by the State of Minnesota may have paid for ineligible participants. Context: Applies to the automated application controls over the population of eligible participants within the program. Questioned Costs: None Repeat Finding?: Yes Recommendation: We suggest that the County encourage the State to provide an independent audit of the design and implementation of HuBERT system controls. View of responsible officials of the auditee: Hennepin County has reviewed and agrees with the finding and recommendation.
Matching Federal Agency: U.S. Department of Housing and Urban Development Program: Continuum of Care Program (ALN 14.267) Federal Assistance Identification Number or Pass-Through Numbers: MN0311L5K002007, MN0364L5K002005, MN0372L5K002105 Federal Award Years: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a), requires that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 24 CFR 578.73(a) requires that the recipient must match all grant funds, except for leasing funds, with no less than 25 percent of funds or in-kind contributions from other sources. For grantees where there is more than one grant agreement, the 25 percent match must be provided on a grant-by-grant basis. Cash match must be used for the costs of activities that are eligible as program costs under 24 CFR 578 Subpart D. 2 CFR 200.306(b)(1) requires that any shared costs or matching funds must be verifiable from the non-Federal entity’s records. Condition: While we were able to test a manual compensating control over matching, we were not able to review and test the automated application controls and related ITGCs within the State’s MAXIS system. The State was not able to provide information regarding the design and implementation of MAXIS system controls, nor were we able to test those controls directly. Cause: The State was not able to provide information regarding the design and effectiveness of MAXIS system controls nor were we able to test those controls directly due to complexities of data privacy and resources within the State. Effect: There is an increased risk of noncompliance with the matching requirement. Context: Applies to the automated application controls over matching. Questioned Costs: None Repeat Finding?: Yes Recommendation: We suggest that the County encourage the State to provide an independent audit of the design and implementation of MAXIS system controls. View of responsible officials of the auditee: Hennepin County has reviewed and agrees with the finding and recommendation.
Eligibility Federal Agency: U.S. Department of Health and Human Services Program: Medical Assistance Program (ALN 93.778) Pass-through Entity: State of Minnesota, Department of Human Services Federal Assistance Identification Number or Pass-Through Numbers: 2005MN5ADM, 2105MN5ADM, 2105MN5MAP, NH23IP922628 Federal Award Years: Year ended December 31, 2023 Type of Finding: Material Weakness in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 2 CFR 200.303(a) requires that each 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." Specific criteria are established with respect to eligibility for assistance and the County’s responsibilities related to the intake function: The Minnesota Health Care Programs Eligibility Policy Manual at 1.3.2.4 requires a County agency to evaluate and pursue resolution of information that is inconsistent with other information. 42 CFR 435.907 requires, as a condition of eligibility, each individual seeking Medicaid must submit a signed application. 42 CFR 435.407 requires, as a condition of eligibility, each individual seeking Medicaid must provide evidence of citizenship. Condition: During our testing, we noted the following 8 instances of noncompliance in the sample of 120 case files tested: Five MAXIS (eligibility determination system) case files had different bases of eligibility in MAXIS and MMIS (payment system). For three of the five cases, MAXIS indicated the beneficiary was “EX” (age 65 or older) while MMIS indicated the beneficiary was “DX” (disabled). For one of the five cases, MAXIS indicated the beneficiary was “1619(b)” (people who no longer receive an SSI cash benefit and maintain their disability status) while MMIS indicated the beneficiary was “DX” (disabled) and the final case indicated the beneficiary was “DC” (disabled child 18-20) in MAXIS while MMIS indicated the beneficiary was “DT” (disabled child under TEFRA option). Two MAXIS case files did not have a signed application on file. One MAXIS case file did not have citizenship verified. In addition, the County does not have a formalized supervisory case file review process in place to ensure accuracy and completeness of inputs into the two eligibility determination systems, MAXIS and METS. Cause: The County relied on the pandemic related continuous eligibility provisions for the Medical Assistance program. Program personnel entering case data into MAXIS or METS did not ensure all required information was input correctly, supported or that all required information was obtained. Effect: Although not found during our testing, benefits paid for participants in the program by the State of Minnesota may have paid for ineligible participants or paid the incorrect amount. Context: The State of Minnesota Department of Human Services (DHS) contracts with county social services departments to perform the “intake function” (meeting with the social services client to determine income and categorical eligibility), while the State maintains the MAXIS and METS systems, which determine eligibility. Participants receive benefit payments from the state. The eligible individuals consist of two populations, and a total of 120 enrolled persons were selected, 60 from the MAXIS system and another 60 from the METS system. The sample sizes were based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Of the 120 selections, errors were noted in seven of the cases (see condition section above for more detail). Questioned Costs: None. The County only receives reimbursement for administrative costs of the program. All benefits paid to participants in the program are paid directly by the State of Minnesota. Repeat Finding?: Yes Recommendation: We recommend the County strengthen internal controls over inputs used to determine eligibility to ensure they are correctly entered and the information required by the contract is retained in the County’s records. View of responsible officials of the auditee: Hennepin County has reviewed and agrees with the finding and recommendation.
Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Federal Agency: U.S. Department of Health and Human Services Program: Foster Care Title IV-E (ALN 93.658) Pass-through Entity: State of Minnesota, Department of Human Services Federal Assistance Identification Number or Pass-Through Number: 2101MNFOST Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that each 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.” Expenditures are to be made for allowable foster care activities and must be in accordance with 2 CFR Part 200, Subpart E. Foster care maintenance payments are allowable if the foster child is removed from home per the requirements of Section 406(a) of the Social Security Act and is placed into foster care by means of a judicial determination. Condition: While we were able to test manual compensating controls over activities allowed or unallowed, allowable costs/cost principles and eligibility, we were not able to review and test the automated application controls and the related ITGCs within the MAXIS and SSIS systems that reside within the State of Minnesota, but are utilized by the County, to determine whether the system controls are adequately designed and implemented and operating effectively. Cause: The State was not able to provide information regarding the design and effectiveness of MAXIS and SSIS system controls nor were we able to test those controls directly due to complexities of data privacy and resources within the State. Effect: Although not found during our testing, benefits paid for participants in the program may have paid for ineligible participants. Context: Applies to the automated application controls over the population of expenditures and eligible participants within the program. Questioned Costs: None noted Repeat Finding?: Yes Recommendation: We suggest that the County encourage the State to provide an independent audit of the design and implementation of MAXIS and SSIS system controls. View of responsible officials of the auditee: Hennepin County has reviewed and agrees with the finding and recommendation.
Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Health and Human Services; U.S. Department of Agriculture (USDA) Program: National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)(ALN 93. 323); Child Support Services (ALN 93. 563); State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (ALN 10.561) Pass-through Entity: Minnesota Department of Health; Minnesota Department of Human Services Federal Assistance Identification Number or Pass-Through Number: U90TP000529; 6NH23P0007370502; NH23P922628; NH23IP922628; NU50CK000508; 2001MNCEST; 2101MNCSES; 212MN127Q7503; 212MN101S2520; 212MN101S2514 Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 2 CFR 200.303(a) requires that each 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 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards awards (the “schedule”) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with ss 200.502... ...At minimum, the schedule must... ...(3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available…” Condition: While testing the SEFA, we noted that internal controls were not operating effectively over the preparation of the SEFA. In addition, we noted the following errors in the original SEFA we received for the audit: - $1,284,631 of expenditures were improperly included in ALN 93.889 when the amount should have been included in ALN 93.268. - $30,394 of expenditures was improperly included in ALN 93.889 when the amount should have been included in ALN 93.323. - $626,894 of expenditures related to ALN 93.563 was missing from the schedule. - $61,290 of expenditures related to ALN 10.561 was missing from the schedule. Cause: The errors of $1,284,631 and $30,394 related to ALN 93.889 were caused by the county hospital’s system of assigning identifying numbers within the chart of accounts not being applied to awards managed outside of the Hennepin Health Foundation. The errors of $626,894 related to ALN 93.563 and $61,290 related to ALN 10.561 related to the County’s reducing expenditures by a reversal of a prior year receivable transaction when determining the amount of expenditures. Effect: The errors in the preparation of the SEFA indicate noncompliance with the requirements for the Schedule, including ensuring that it is complete and accurate. Context: Approximately $2 million of errors were noted over the SEFA with total expenditures of approximately $360 million. Questioned Costs: None Repeat Finding?: No Recommendation: We recommend that the County strengthen its processes and controls over the preparation of the SEFA. Views of Responsible Officials: Hennepin County has reviewed and agrees with the finding and the recommendation.
Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Health and Human Services; U.S. Department of Agriculture (USDA) Program: National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)(ALN 93. 323); Child Support Services (ALN 93. 563); State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (ALN 10.561) Pass-through Entity: Minnesota Department of Health; Minnesota Department of Human Services Federal Assistance Identification Number or Pass-Through Number: U90TP000529; 6NH23P0007370502; NH23P922628; NH23IP922628; NU50CK000508; 2001MNCEST; 2101MNCSES; 212MN127Q7503; 212MN101S2520; 212MN101S2514 Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 2 CFR 200.303(a) requires that each 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 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards awards (the “schedule”) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with ss 200.502... ...At minimum, the schedule must... ...(3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available…” Condition: While testing the SEFA, we noted that internal controls were not operating effectively over the preparation of the SEFA. In addition, we noted the following errors in the original SEFA we received for the audit: - $1,284,631 of expenditures were improperly included in ALN 93.889 when the amount should have been included in ALN 93.268. - $30,394 of expenditures was improperly included in ALN 93.889 when the amount should have been included in ALN 93.323. - $626,894 of expenditures related to ALN 93.563 was missing from the schedule. - $61,290 of expenditures related to ALN 10.561 was missing from the schedule. Cause: The errors of $1,284,631 and $30,394 related to ALN 93.889 were caused by the county hospital’s system of assigning identifying numbers within the chart of accounts not being applied to awards managed outside of the Hennepin Health Foundation. The errors of $626,894 related to ALN 93.563 and $61,290 related to ALN 10.561 related to the County’s reducing expenditures by a reversal of a prior year receivable transaction when determining the amount of expenditures. Effect: The errors in the preparation of the SEFA indicate noncompliance with the requirements for the Schedule, including ensuring that it is complete and accurate. Context: Approximately $2 million of errors were noted over the SEFA with total expenditures of approximately $360 million. Questioned Costs: None Repeat Finding?: No Recommendation: We recommend that the County strengthen its processes and controls over the preparation of the SEFA. Views of Responsible Officials: Hennepin County has reviewed and agrees with the finding and the recommendation.
Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Health and Human Services; U.S. Department of Agriculture (USDA) Program: National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)(ALN 93. 323); Child Support Services (ALN 93. 563); State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (ALN 10.561) Pass-through Entity: Minnesota Department of Health; Minnesota Department of Human Services Federal Assistance Identification Number or Pass-Through Number: U90TP000529; 6NH23P0007370502; NH23P922628; NH23IP922628; NU50CK000508; 2001MNCEST; 2101MNCSES; 212MN127Q7503; 212MN101S2520; 212MN101S2514 Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 2 CFR 200.303(a) requires that each 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 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards awards (the “schedule”) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with ss 200.502... ...At minimum, the schedule must... ...(3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available…” Condition: While testing the SEFA, we noted that internal controls were not operating effectively over the preparation of the SEFA. In addition, we noted the following errors in the original SEFA we received for the audit: - $1,284,631 of expenditures were improperly included in ALN 93.889 when the amount should have been included in ALN 93.268. - $30,394 of expenditures was improperly included in ALN 93.889 when the amount should have been included in ALN 93.323. - $626,894 of expenditures related to ALN 93.563 was missing from the schedule. - $61,290 of expenditures related to ALN 10.561 was missing from the schedule. Cause: The errors of $1,284,631 and $30,394 related to ALN 93.889 were caused by the county hospital’s system of assigning identifying numbers within the chart of accounts not being applied to awards managed outside of the Hennepin Health Foundation. The errors of $626,894 related to ALN 93.563 and $61,290 related to ALN 10.561 related to the County’s reducing expenditures by a reversal of a prior year receivable transaction when determining the amount of expenditures. Effect: The errors in the preparation of the SEFA indicate noncompliance with the requirements for the Schedule, including ensuring that it is complete and accurate. Context: Approximately $2 million of errors were noted over the SEFA with total expenditures of approximately $360 million. Questioned Costs: None Repeat Finding?: No Recommendation: We recommend that the County strengthen its processes and controls over the preparation of the SEFA. Views of Responsible Officials: Hennepin County has reviewed and agrees with the finding and the recommendation.
Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Health and Human Services; U.S. Department of Agriculture (USDA) Program: National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)(ALN 93. 323); Child Support Services (ALN 93. 563); State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (ALN 10.561) Pass-through Entity: Minnesota Department of Health; Minnesota Department of Human Services Federal Assistance Identification Number or Pass-Through Number: U90TP000529; 6NH23P0007370502; NH23P922628; NH23IP922628; NU50CK000508; 2001MNCEST; 2101MNCSES; 212MN127Q7503; 212MN101S2520; 212MN101S2514 Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 2 CFR 200.303(a) requires that each 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 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards awards (the “schedule”) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with ss 200.502... ...At minimum, the schedule must... ...(3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available…” Condition: While testing the SEFA, we noted that internal controls were not operating effectively over the preparation of the SEFA. In addition, we noted the following errors in the original SEFA we received for the audit: - $1,284,631 of expenditures were improperly included in ALN 93.889 when the amount should have been included in ALN 93.268. - $30,394 of expenditures was improperly included in ALN 93.889 when the amount should have been included in ALN 93.323. - $626,894 of expenditures related to ALN 93.563 was missing from the schedule. - $61,290 of expenditures related to ALN 10.561 was missing from the schedule. Cause: The errors of $1,284,631 and $30,394 related to ALN 93.889 were caused by the county hospital’s system of assigning identifying numbers within the chart of accounts not being applied to awards managed outside of the Hennepin Health Foundation. The errors of $626,894 related to ALN 93.563 and $61,290 related to ALN 10.561 related to the County’s reducing expenditures by a reversal of a prior year receivable transaction when determining the amount of expenditures. Effect: The errors in the preparation of the SEFA indicate noncompliance with the requirements for the Schedule, including ensuring that it is complete and accurate. Context: Approximately $2 million of errors were noted over the SEFA with total expenditures of approximately $360 million. Questioned Costs: None Repeat Finding?: No Recommendation: We recommend that the County strengthen its processes and controls over the preparation of the SEFA. Views of Responsible Officials: Hennepin County has reviewed and agrees with the finding and the recommendation.
Schedule of Expenditures of Federal Awards (SEFA) Federal Agency: U.S. Department of Health and Human Services; U.S. Department of Agriculture (USDA) Program: National Bioterrorism Hospital Preparedness Program (ALN 93.889); Immunization Cooperative Agreements (ALN 93. 268); COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)(ALN 93. 323); Child Support Services (ALN 93. 563); State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (ALN 10.561) Pass-through Entity: Minnesota Department of Health; Minnesota Department of Human Services Federal Assistance Identification Number or Pass-Through Number: U90TP000529; 6NH23P0007370502; NH23P922628; NH23IP922628; NU50CK000508; 2001MNCEST; 2101MNCSES; 212MN127Q7503; 212MN101S2520; 212MN101S2514 Federal Award Year: Year ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matter Compliance Finding Criteria: 2 CFR 200.303(a) requires that each 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 200.510(b) requires that “The auditee must prepare a schedule of expenditures of Federal awards awards (the “schedule”) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with ss 200.502... ...At minimum, the schedule must... ...(3) Provide total Federal awards expended for each individual Federal program and the Assistance Listings Number or other identifying number when the Assistance Listings information is not available…” Condition: While testing the SEFA, we noted that internal controls were not operating effectively over the preparation of the SEFA. In addition, we noted the following errors in the original SEFA we received for the audit: - $1,284,631 of expenditures were improperly included in ALN 93.889 when the amount should have been included in ALN 93.268. - $30,394 of expenditures was improperly included in ALN 93.889 when the amount should have been included in ALN 93.323. - $626,894 of expenditures related to ALN 93.563 was missing from the schedule. - $61,290 of expenditures related to ALN 10.561 was missing from the schedule. Cause: The errors of $1,284,631 and $30,394 related to ALN 93.889 were caused by the county hospital’s system of assigning identifying numbers within the chart of accounts not being applied to awards managed outside of the Hennepin Health Foundation. The errors of $626,894 related to ALN 93.563 and $61,290 related to ALN 10.561 related to the County’s reducing expenditures by a reversal of a prior year receivable transaction when determining the amount of expenditures. Effect: The errors in the preparation of the SEFA indicate noncompliance with the requirements for the Schedule, including ensuring that it is complete and accurate. Context: Approximately $2 million of errors were noted over the SEFA with total expenditures of approximately $360 million. Questioned Costs: None Repeat Finding?: No Recommendation: We recommend that the County strengthen its processes and controls over the preparation of the SEFA. Views of Responsible Officials: Hennepin County has reviewed and agrees with the finding and the recommendation.
FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 20-1892-0-1-806 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The County elected to receive the standard revenue loss allowance, allowing it to claim its total COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) allocation of $3,723,354 as revenue loss to use for government services. As such, all SLFRF program funds to date were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients' use of revenue loss funds would not give rise to subrecipient relationships as there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with the SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. The County did not have any policies or procedures in place related to the suspension and debarment requirements. A population of 12 covered transactions, totaling $1,038,900, that equaled or exceeded $25,000 paid from SLFRF funds were identified. Of the 12 covered transactions, there were 4, totaling $441,145, that were selected for testing. For each of the 4 transactions, the County did not verify the vendors' suspension or debarment status prior to payment due to the County not having any policies or procedures in place to verify that contractors were neither suspended nor debarred or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 18 PERRY COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) 2 CFR 200.214 states: "Non-federal entities and contractors are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. 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." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person" Cause The County's purchasing policy does not include procedures to verify suspension and debarment status for covered transactions it intends to pay with federal funds. Effect Without the proper implementation of an effectively designed system of internal controls, the County cannot ensure that contractors paid with federal funds are eligible to participate in federal programs. Any program funds the County used to pay contractors that have been suspended or debarred would be unallowable, and the funding agency could potentially recover them. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommend that management of the County strengthen its system of internal controls to ensure that all contractors that are paid $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs before entering into contracts. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Fund Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): 20-1892-0-1-806 Compliance Requirement: Reporting Audit Findings: Material Weakness, Other Matters Condition and Context Recipients are required to quarterly or annually submit Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation less than $10 million in COVID-19 - Coronavirus State and Local Fiscal Recovery Funds (SLFRF) award funds. As such, the initial P&E report, covering the period from March 3, 2021 to March 31, 2022, was required to be submitted to the Treasury by April 30, 2022. The subsequent annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. The County submitted one P&E report during the audit period. Although the Deputy County Auditor compiled the information for the report and the County Auditor reviewed and submitted the report, the internal controls were not effective in preventing, or detecting and correcting, errors. As a result, the P&E report contained the following errors: The current period expenditures were overstated by $336,376. The cumulative expenditures were understated by $18,624. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." INDIANA STATE BOARD OF ACCOUNTS 20 PERRY COUNTY SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guidance, page 10, states in part: ". . . 10. Reporting. All recipients of federal funds must complete financial, performance, and compliance reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with appropriate accounting standards and principles. . . ." Cause The County's internal controls were not effective to prevent and detect errors on the P&E report prior to submission. The County did not insure that information reported was correct and applicable to the reporting period of the submission. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As such, the County did not accurately report current period expenditures and total cumulative expenditures properly when filing the P&E report for the period from April 1, 2022 to March 31, 2023. Not properly reporting the information to the Treasury provides the Treasury with an inaccurate picture of the County's activity for the reporting period. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County develop policies and procedures to ensure the County accurately reports current period and cumulative expenditures on the P&E report to the Treasury. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.