Finding 1102311 (2023-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2025-03-06
Audit: 345033
Organization: County of Solano (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to include required federal award identification elements in the subrecipient agreement and did not conduct a timely risk assessment before the fiscal year 2023.
  • Impacted Requirements: Noncompliance with 2 CFR 200.331 regarding subrecipient agreements, risk assessments, and monitoring activities.
  • Recommended Follow-up: Strengthen policies to ensure risk assessments are completed before awards and document monitoring results effectively.

Finding Text

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management decision. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 525869 2023-002
    Material Weakness Repeat
  • 525870 2023-002
    Material Weakness Repeat
  • 525871 2023-003
    Material Weakness Repeat
  • 525872 2023-003
    Material Weakness Repeat
  • 525873 2023-004
    - Repeat
  • 525874 2023-004
    - Repeat
  • 525875 2023-004
    - Repeat
  • 525876 2023-005
    Material Weakness Repeat
  • 525877 2023-005
    Material Weakness Repeat
  • 525878 2023-005
    Material Weakness Repeat
  • 525879 2023-006
    - Repeat
  • 525880 2023-006
    - Repeat
  • 525881 2023-006
    - Repeat
  • 525882 2023-007
    Material Weakness
  • 525883 2023-008
    Material Weakness
  • 525884 2023-008
    Material Weakness
  • 525885 2023-008
    Material Weakness
  • 1102312 2023-002
    Material Weakness Repeat
  • 1102313 2023-003
    Material Weakness Repeat
  • 1102314 2023-003
    Material Weakness Repeat
  • 1102315 2023-004
    - Repeat
  • 1102316 2023-004
    - Repeat
  • 1102317 2023-004
    - Repeat
  • 1102318 2023-005
    Material Weakness Repeat
  • 1102319 2023-005
    Material Weakness Repeat
  • 1102320 2023-005
    Material Weakness Repeat
  • 1102321 2023-006
    - Repeat
  • 1102322 2023-006
    - Repeat
  • 1102323 2023-006
    - Repeat
  • 1102324 2023-007
    Material Weakness
  • 1102325 2023-008
    Material Weakness
  • 1102326 2023-008
    Material Weakness
  • 1102327 2023-008
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.563 Child Support Enforcement $7.68M
20.205 Highway Planning and Construction $3.38M
14.871 Section 8 Housing Choice Vouchers $3.13M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $2.71M
93.778 Medical Assistance Program $2.36M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.73M
93.224 Covid-19 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.31M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $826,610
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $596,260
16.575 Crime Victim Assistance $593,209
93.659 Adoption Assistance $553,181
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $505,023
93.498 Covid-19 Provider Relief Fund $463,799
93.994 Maternal and Child Health Services Block Grant to the States $388,673
16.738 Edward Byrne Memorial Justice Assistance Grant Program $349,914
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $341,429
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $334,090
93.667 Social Services Block Grant $329,728
93.658 Foster Care_title IV-E $312,354
93.556 Promoting Safe and Stable Families $301,061
16.606 State Criminal Alien Assistance Program $298,259
93.052 National Family Caregiver Support, Title Iii, Part E $291,617
97.067 Homeland Security Grant Program $251,279
93.889 National Bioterrorism Hospital Preparedness Program $240,451
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $226,463
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $217,908
93.526 Covid-19 Affordable Care Act (aca) Grants for Capital Development in Health Centers $211,510
93.069 Public Health Emergency Preparedness $208,837
93.053 Nutrition Services Incentive Program $207,308
93.268 Immunization Cooperative Agreements $182,180
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $161,633
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $148,008
17.258 Wia Adult Program $139,508
93.645 Stephanie Tubbs Jones Child Welfare Services Program $134,957
20.616 National Priority Safety Programs $127,440
93.958 Covid-19 Block Grants for Community Mental Health Services $120,486
17.278 Wia Dislocated Worker Formula Grants $113,074
93.958 Block Grants for Community Mental Health Services $106,592
59.037 Small Business Development Centers $104,192
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $97,487
93.090 Guardianship Assistance $85,194
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $85,050
93.940 Hiv Prevention Activities_health Department Based $82,288
93.747 Elder Abuse Prevention Interventions Program $72,639
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $72,071
93.558 Temporary Assistance for Needy Families $71,379
14.879 Mainstream Vouchers $66,358
14.896 Family Self-Sufficiency Program $60,668
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $49,554
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $47,877
97.042 Emergency Management Performance Grants $46,060
15.605 Sport Fish Restoration Program $45,942
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $43,042
17.277 Workforce Investment Act (wia) National Emergency Grants $42,869
93.590 Community-Based Child Abuse Prevention Grants $35,923
93.150 Projects for Assistance in Transition From Homelessness (path) $35,911
93.044 Covid-19 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $25,037
17.259 Wia Youth Activities $25,003
93.917 Hiv Care Formula Grants $22,479
93.197 Childhood Lead Poisoning Prevention Projects_state and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $19,857
93.959 Block Grants for Prevention and Treatment of Substance Abuse $19,601
16.U02 Safe Streets Violent Crimes Initiative $17,387
16.U03 2022 Domestic Cannabis Eradication Suppression Program $15,381
10.025 Plant and Animal Disease, Pest Control, and Animal Care $15,079
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $6,795
93.603 Adoption Incentive Payments $6,196
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $4,169
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $3,144
93.747 Covid-19 Elder Abuse Prevention Interventions Program $2,171
93.042 Covid-19 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,562
16.U04 2023 Domestic Cannabis Eradication Suppression Program $1,435
20.106 Covid-19 Airport Improvement Program $527
93.566 Refugee and Entrant Assistance_state Administered Programs $195
93.045 Covid-19 Special Programs for the Aging_title Iii, Part C_nutrition Services $105