Finding 1135561 (2024-010)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-05-02
Audit: 355375
Organization: County of Ventura (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to verify if a contractor was suspended or debarred before entering into a contract, and did not maintain adequate procurement documentation.
  • Impacted Requirements: Non-compliance with 2 CFR sections 200.303(a), 200.214, and 200.318(i) regarding internal controls and procurement records.
  • Recommended Follow-Up: Strengthen policies to ensure proper verification of contractor eligibility, maintain thorough procurement records, and include all necessary contract provisions as per 2 CFR 200 Appendix II.

Finding Text

Program: COVID-19 Health Center Program Cluster Assistance Listing No.: 93.224; 93.527 Federal Grantor: U.S. Department of Health and Human Services Passed-through: N/A Award No.: 4 H8GCS48295‐01‐01 Award Year: 12/01/2022 ‐ 12/31/2023 Compliance Requirement: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance and Material Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Title 2 CFR Section 200.214 of the Uniform Guidance states that the County must comply with 2 CFR part 180, which implements Executive Orders 12549 and 12689. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Per 2 CFR Section 180.300, when a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.sam.gov/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. 2 CFR 200.327 Contract provisions. The recipient's or subrecipient's contracts must contain the applicable provisions described in Appendix II to Part 200—Contract Provisions for Non-Federal Entity Contracts Under Federal Awards. Condition: During our testing of the County’s provisions for procurement requirements, we noted the following: 1. For one (1) out of three (3) contracts selected for testing, there was no evidence that the County verified the entity was not suspended or debarred or otherwise excluded from participating in the transaction, prior to entering the contract. 2. For one (1) out of three (3) contracts selected for testing, the County did not include all applicable provisions described in 2 CFR 200 Appendix II. 3. For one (1) out of three (3) contracts selected for testing with a total contract value of $2,616,000, the County could not provide documentation of the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Cause: The County did not follow their policy to verify the information described in the condition prior to entering the transactions. The County did not follow their policy documenting the history of the procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. The County’s policy does not include the requirement to include all applicable provisions identified in 2 CFR 200 Appendix II in its contracts. Effect: Failure to implement and maintain a proper control process could result in payments to vendors that are suspended or debarred or improper awarding of contracts under the procurement guidance. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of three (3) out of three (3) procurement contracts were tested. This represented a total of $21,679,640 in contracted services under the grant. Repeat Finding from Prior Years: No. Recommendation: We recommend the County strengthen its policies and procedures to ensure that the verification of the debarment and suspension is documented and retained, the history of procurement transactions is documented and retained in its official records, and that contracts include all applicable provisions of 2 CFR 200 Appendix II. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 559079 2024-002
    Material Weakness
  • 559080 2024-003
    Significant Deficiency
  • 559081 2024-002
    Material Weakness
  • 559082 2024-003
    Significant Deficiency
  • 559083 2024-002
    Material Weakness
  • 559084 2024-003
    Significant Deficiency
  • 559085 2024-007
    Significant Deficiency
  • 559086 2024-008
    Material Weakness
  • 559087 2024-009
    Material Weakness
  • 559088 2024-007
    Significant Deficiency
  • 559089 2024-008
    Material Weakness
  • 559090 2024-009
    Material Weakness
  • 559091 2024-007
    Significant Deficiency
  • 559092 2024-008
    Material Weakness
  • 559093 2024-009
    Material Weakness
  • 559094 2024-007
    Significant Deficiency
  • 559095 2024-008
    Material Weakness
  • 559096 2024-009
    Material Weakness
  • 559097 2024-007
    Significant Deficiency
  • 559098 2024-008
    Material Weakness
  • 559099 2024-009
    Material Weakness
  • 559100 2024-007
    Significant Deficiency
  • 559101 2024-008
    Material Weakness
  • 559102 2024-009
    Material Weakness
  • 559103 2024-004
    Material Weakness
  • 559104 2024-004
    Material Weakness
  • 559105 2024-004
    Material Weakness
  • 559106 2024-004
    Material Weakness
  • 559107 2024-004
    Material Weakness
  • 559108 2024-004
    Material Weakness
  • 559109 2024-004
    Material Weakness
  • 559110 2024-004
    Material Weakness
  • 559111 2024-004
    Material Weakness
  • 559112 2024-004
    Material Weakness
  • 559113 2024-004
    Material Weakness
  • 559114 2024-004
    Material Weakness
  • 559115 2024-004
    Material Weakness
  • 559116 2024-004
    Material Weakness
  • 559117 2024-004
    Material Weakness
  • 559118 2024-004
    Material Weakness
  • 559119 2024-010
    Material Weakness
  • 559120 2024-010
    Material Weakness
  • 559121 2024-010
    Material Weakness
  • 559122 2024-010
    Material Weakness
  • 559123 2024-005
    Material Weakness
  • 559124 2024-006
    Material Weakness
  • 559125 2024-005
    Material Weakness
  • 559126 2024-006
    Material Weakness
  • 559127 2024-005
    Material Weakness
  • 559128 2024-006
    Material Weakness
  • 559129 2024-005
    Material Weakness
  • 559130 2024-006
    Material Weakness
  • 559131 2024-005
    Material Weakness
  • 559132 2024-006
    Material Weakness
  • 559133 2024-005
    Material Weakness
  • 559134 2024-006
    Material Weakness
  • 559135 2024-005
    Material Weakness
  • 559136 2024-006
    Material Weakness
  • 559137 2024-005
    Material Weakness
  • 559138 2024-006
    Material Weakness
  • 559139 2024-005
    Material Weakness
  • 559140 2024-006
    Material Weakness
  • 559141 2024-005
    Material Weakness
  • 559142 2024-006
    Material Weakness
  • 1135521 2024-002
    Material Weakness
  • 1135522 2024-003
    Significant Deficiency
  • 1135523 2024-002
    Material Weakness
  • 1135524 2024-003
    Significant Deficiency
  • 1135525 2024-002
    Material Weakness
  • 1135526 2024-003
    Significant Deficiency
  • 1135527 2024-007
    Significant Deficiency
  • 1135528 2024-008
    Material Weakness
  • 1135529 2024-009
    Material Weakness
  • 1135530 2024-007
    Significant Deficiency
  • 1135531 2024-008
    Material Weakness
  • 1135532 2024-009
    Material Weakness
  • 1135533 2024-007
    Significant Deficiency
  • 1135534 2024-008
    Material Weakness
  • 1135535 2024-009
    Material Weakness
  • 1135536 2024-007
    Significant Deficiency
  • 1135537 2024-008
    Material Weakness
  • 1135538 2024-009
    Material Weakness
  • 1135539 2024-007
    Significant Deficiency
  • 1135540 2024-008
    Material Weakness
  • 1135541 2024-009
    Material Weakness
  • 1135542 2024-007
    Significant Deficiency
  • 1135543 2024-008
    Material Weakness
  • 1135544 2024-009
    Material Weakness
  • 1135545 2024-004
    Material Weakness
  • 1135546 2024-004
    Material Weakness
  • 1135547 2024-004
    Material Weakness
  • 1135548 2024-004
    Material Weakness
  • 1135549 2024-004
    Material Weakness
  • 1135550 2024-004
    Material Weakness
  • 1135551 2024-004
    Material Weakness
  • 1135552 2024-004
    Material Weakness
  • 1135553 2024-004
    Material Weakness
  • 1135554 2024-004
    Material Weakness
  • 1135555 2024-004
    Material Weakness
  • 1135556 2024-004
    Material Weakness
  • 1135557 2024-004
    Material Weakness
  • 1135558 2024-004
    Material Weakness
  • 1135559 2024-004
    Material Weakness
  • 1135560 2024-004
    Material Weakness
  • 1135562 2024-010
    Material Weakness
  • 1135563 2024-010
    Material Weakness
  • 1135564 2024-010
    Material Weakness
  • 1135565 2024-005
    Material Weakness
  • 1135566 2024-006
    Material Weakness
  • 1135567 2024-005
    Material Weakness
  • 1135568 2024-006
    Material Weakness
  • 1135569 2024-005
    Material Weakness
  • 1135570 2024-006
    Material Weakness
  • 1135571 2024-005
    Material Weakness
  • 1135572 2024-006
    Material Weakness
  • 1135573 2024-005
    Material Weakness
  • 1135574 2024-006
    Material Weakness
  • 1135575 2024-005
    Material Weakness
  • 1135576 2024-006
    Material Weakness
  • 1135577 2024-005
    Material Weakness
  • 1135578 2024-006
    Material Weakness
  • 1135579 2024-005
    Material Weakness
  • 1135580 2024-006
    Material Weakness
  • 1135581 2024-005
    Material Weakness
  • 1135582 2024-006
    Material Weakness
  • 1135583 2024-005
    Material Weakness
  • 1135584 2024-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.563 Child Support Services $14.79M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $3.57M
93.090 Guardianship Assistance $2.49M
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $1.83M
14.228 Covid-19 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $1.47M
20.205 Highway Planning and Construction $1.28M
93.268 Covid-19 Immunization Cooperative Agreements $978,241
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $887,812
17.270 Reentry Employment Opportunities $776,084
93.658 Foster Care Title IV-E $758,652
93.958 Block Grants for Community Mental Health Services $756,956
90.401 Help America Vote Act Requirements Payments $679,444
93.659 Adoption Assistance $637,841
93.556 Marylee Allen Promoting Safe and Stable Families Program $624,197
14.218 Covid-19 Community Development Block Grants/entitlement Grants $614,541
93.008 Medical Reserve Corps Small Grant Program $600,000
93.667 Social Services Block Grant $595,460
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $585,135
16.606 State Criminal Alien Assistance Program $578,012
16.922 Equitable Sharing Program $530,107
93.526 Covid-19 Grants for Capital Development in Health Centers $508,552
93.959 Block Grants for Prevention and Treatment of Substance Abuse $508,169
14.241 Housing Opportunities for Persons with Aids $495,768
21.032 Local Assistance and Tribal Consistency Fund $470,167
93.994 Maternal and Child Health Services Block Grant to the States $451,758
93.224 Health Center Program (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $437,146
93.052 National Family Caregiver Support, Title Iii, Part E $432,003
17.259 Wioa Youth Activities $407,241
20.507 Federal Transit Formula Grants $405,980
14.920 Lead Hazard Control for High Risk Areas $405,787
14.231 Covid-19 Emergency Solutions Grant Program $396,654
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $364,753
93.645 Stephanie Tubbs Jones Child Welfare Services Program $364,481
16.753 Congressionally Recommended Awards $359,193
14.267 Continuum of Care Program $355,148
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $351,842
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $338,190
17.278 Wioa Dislocated Worker Formula Grants $334,120
16.575 Crime Victim Assistance $310,647
93.558 Temporary Assistance for Needy Families $303,599
93.889 National Bioterrorism Hospital Preparedness Program $286,602
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $280,177
16.320 Services for Trafficking Victims $278,152
93.778 Medical Assistance Program $260,269
16.812 Second Chance Act Reentry Initiative $253,034
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $250,000
10.025 Plant and Animal Disease, Pest Control, and Animal Care $218,769
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $202,041
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $196,524
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $181,235
93.053 Nutrition Services Incentive Program $176,173
66.046 Climate Pollution Reduction Grants $165,739
93.268 Immunization Cooperative Agreements $165,572
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $155,015
14.231 Emergency Solutions Grant Program $146,267
14.239 Home Investment Partnerships Program $142,194
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $123,128
97.042 Emergency Management Performance Grants $122,527
93.150 Projects for Assistance in Transition From Homelessness (path) $115,598
97.067 Homeland Security Grant Program $111,651
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $106,992
10.555 National School Lunch Program $102,817
16.741 Dna Backlog Reduction Program $100,465
21.016 Equitable Sharing $99,841
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $96,491
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $92,042
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $84,557
17.258 Wioa Adult Program $83,979
93.048 Covid-19 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $79,128
20.106 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs $76,999
93.527 Covid-19 Grants for New and Expanded Services Under the Health Center Program $74,551
93.470 Alzheimer’s Disease Program Initiative (adpi) $72,471
84.126 Rehabilitation Services Vocational Rehabilitation Grants to States $70,456
16.833 National Sexual Assault Kit Initiative $69,906
93.324 State Health Insurance Assistance Program $67,972
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $67,781
93.917 Hiv Care Formula Grants $65,638
97.044 Assistance to Firefighters Grant $65,364
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $64,632
93.043 Covid-19 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $62,338
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $60,284
90.404 Hava Election Security Grants $58,380
20.600 State and Community Highway Safety $57,697
93.042 Special Programs for the Aging, Title Vii, Chapter 2, Long Term Care Ombudsman Services for Older Individuals $57,613
16.710 Public Safety Partnership and Community Policing Grants $56,673
20.616 National Priority Safety Programs $55,735
97.039 Hazard Mitigation Grant $52,825
14.912 Lead Hazard Control Capacity Building $52,661
10.553 School Breakfast Program $48,588
10.665 Schools and Roads - Grants to States $47,195
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $44,641
93.069 Public Health Emergency Preparedness $43,227
93.071 Medicare Enrollment Assistance Program $39,980
16.U01 Eradication Suppression Fy 2023 Dea Domestic Cannabis Eradication Suppression Progrgram $33,176
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $29,193
14.218 Community Development Block Grants/entitlement Grants $26,070
45.129 Promotion of the Humanities Federal/state Partnership $22,450
17.235 Senior Community Service Employment Program $21,750
16.738 Edward Byrne Memorial Justice Assistance Grant Program $9,156
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $6,253
21.023 Covid-19 Emergency Rental Assistance Program $3,508