Finding 1062086 (2023-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-03
Audit: 318441
Organization: Oconto County, Wisconsin (WI)

AI Summary

  • Core Issue: The County lacks procedures to ensure compliance with suspension and debarment requirements for federal funding.
  • Impacted Requirements: Nonfederal entities must verify that contractors are not suspended or debarred under 2 CFR 200 and 180.
  • Recommended Follow-Up: Establish and implement policies for suspension and debarment verification to ensure compliance with federal regulations.

Finding Text

Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 Federal Award Identification Number and Year: SLFRP0756; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County’s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: Yes; 2022-003

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 485643 2023-002
    Material Weakness
  • 485644 2023-003
    Material Weakness Repeat
  • 485645 2023-002
    Material Weakness
  • 485646 2023-003
    Material Weakness Repeat
  • 1062085 2023-002
    Material Weakness
  • 1062087 2023-002
    Material Weakness
  • 1062088 2023-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $336,566
93.778 Medical Assistance Program $326,376
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $253,801
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $119,168
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $118,951
21.019 Coronavirus Relief Fund $111,239
10.912 Environmental Quality Incentives Program $86,289
93.069 Public Health Emergency Preparedness $66,839
97.042 Emergency Management Performance Grants $51,842
93.090 Guardianship Assistance $46,247
84.181 Special Education-Grants for Infants and Families $36,543
93.658 Foster Care_title IV-E $21,878
93.767 Children's Health Insurance Program $20,236
66.469 Great Lakes Program $19,818
93.994 Maternal and Child Health Services Block Grant to the States $13,817
16.710 Public Safety Partnership and Community Policing Grants $13,516
93.958 Block Grants for Community Mental Health Services $13,353
93.959 Block Grants for Prevention and Treatment of Substance Abuse $12,242
93.558 Temporary Assistance for Needy Families $10,587
20.219 Recreational Trails Program $10,017
93.747 Elder Abuse Prevention Interventions Program $8,137
93.991 Preventive Health and Health Services Block Grant $6,223
93.563 Child Support Enforcement $5,830
93.667 Social Services Block Grant $3,574
16.607 Bulletproof Vest Partnership Program $3,403
93.575 Child Care and Development Block Grant $2,240
93.268 Immunization Cooperative Agreements $1,636
93.645 Stephanie Tubbs Jones Child Welfare Services Program $1,342
93.556 Promoting Safe and Stable Families $1,187
93.659 Adoption Assistance $301
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $-6,607