FAC Explorer

Finding 1062106 (2023-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-04
Audit: 318475
Organization: Brown County, Wisconsin (WI)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The County's procurement policies do not comply with federal suspension and debarment requirements, risking payments to ineligible vendors.
  • Impacted Requirements: Noncompliance with 2 CFR 200, which prohibits contracting with suspended or debarred entities in covered transactions.
  • Recommended Follow-Up: Update procurement policies to align with 2 CFR 200 and ensure compliance for all federal grants.

Finding Text

2023-002 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 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters 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 While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. 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 Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.

Categories

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

Other Findings in this Audit

  • 485663 2023-002
    Significant Deficiency Repeat
  • 485664 2023-002
    Significant Deficiency Repeat
  • 485665 2023-002
    Significant Deficiency Repeat
  • 485666 2023-002
    Significant Deficiency Repeat
  • 485667 2023-002
    Significant Deficiency Repeat
  • 485668 2023-002
    Significant Deficiency Repeat
  • 485669 2023-002
    Significant Deficiency Repeat
  • 1062105 2023-002
    Significant Deficiency Repeat
  • 1062107 2023-002
    Significant Deficiency Repeat
  • 1062108 2023-002
    Significant Deficiency Repeat
  • 1062109 2023-002
    Significant Deficiency Repeat
  • 1062110 2023-002
    Significant Deficiency Repeat
  • 1062111 2023-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $45.29M
21.023 Emergency Rental Assistance Program $3.90M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $1.83M
93.778 Medical Assistance Program $970,515
84.425 Education Stabilization Fund $503,590
20.205 Highway Planning and Construction $351,249
84.181 Special Education-Grants for Infants and Families $297,115
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $295,856
16.585 Drug Court Discretionary Grant Program $230,578
93.090 Guardianship Assistance $195,498
93.658 Foster Care_title IV-E $151,666
93.767 Children's Health Insurance Program $145,879
20.106 Airport Improvement Program $141,783
15.658 Natural Resource Damage Assessment, Restoration and Implementation $135,367
95.001 High Intensity Drug Trafficking Areas Program $134,335
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $131,810
97.042 Emergency Management Performance Grants $122,204
16.588 Violence Against Women Formula Grants $106,237
10.902 Soil and Water Conservation $97,938
93.994 Maternal and Child Health Services Block Grant to the States $95,204
16.575 Crime Victim Assistance $92,220
93.563 Child Support Enforcement $81,189
16.922 Equitable Sharing Program $74,091
16.606 State Criminal Alien Assistance Program $67,665
93.556 Promoting Safe and Stable Families $66,620
16.738 Edward Byrne Memorial Justice Assistance Grant Program $49,024
11.473 Office for Coastal Management $48,791
93.558 Temporary Assistance for Needy Families $41,213
93.747 Elder Abuse Prevention Interventions Program $37,994
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $37,366
66.454 Water Quality Management Planning $30,000
93.659 Adoption Assistance $29,367
93.268 Immunization Cooperative Agreements $27,160
93.597 Grants to States for Access and Visitation Programs $26,364
93.958 Block Grants for Community Mental Health Services $25,717
93.667 Social Services Block Grant $24,778
93.568 Low-Income Home Energy Assistance $24,719
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $20,002
93.991 Preventive Health and Health Services Block Grant $19,423
66.469 Great Lakes Program $17,345
10.912 Environmental Quality Incentives Program $17,260
14.218 Community Development Block Grants/entitlement Grants $17,000
66.460 Nonpoint Source Implementation Grants $16,828
20.600 State and Community Highway Safety $12,881
16.710 Public Safety Partnership and Community Policing Grants $11,783
10.555 National School Lunch Program $11,533
93.645 Stephanie Tubbs Jones Child Welfare Services Program $9,304
93.788 Opioid Str $8,949
93.959 Block Grants for Prevention and Treatment of Substance Abuse $7,748
97.067 Homeland Security Grant Program $7,500
20.616 National Priority Safety Programs $7,265
93.575 Child Care and Development Block Grant $6,400
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $5,856
10.553 School Breakfast Program $5,833
16.543 Missing Children's Assistance $4,340
93.069 Public Health Emergency Preparedness $3,685
16.U01 Dea Cease Program $1,900
11.419 Coastal Zone Management Administration Awards $1,395
11.035 Broadband Equity, Access, & Deployment Program $1,000
84.367 Improving Teacher Quality State Grants $311