Finding 1239009 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 413878
Organization: Allen County (IN)

AI Summary

  • Core Issue: The County failed to effectively verify that vendors were not suspended or debarred before entering into contracts exceeding $25,000.
  • Impacted Requirements: Compliance with federal regulations requiring verification of vendor status under 2 CFR 200.303 and 31 CFR 19.300 was not met.
  • Recommended Follow-Up: Management should implement a robust internal control system and ensure all staff are trained on compliance requirements and policies.

Finding Text

FINDING 2025-003 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): FY 2025 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition and Context Prior to entering into subawards and covered transactions with the COVID-19 - State and Local Fiscal Recovery Funds (SLFRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended and 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 either; 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 vendor. The County had policies and procedures in place to verify that a vendor with which it planned to enter into a covered transaction was not suspended and debarred or otherwise excluded, but its policies and procedures were not effective in ensuring all vendors were verified. A sample of two vendors was selected for testing the suspension and debarment requirements; however, documentation supporting the County's compliance with its suspension and debarment verification policies was not provided for audit for either vendor selected. The lack of effective internal controls and noncompliance were systemic issues throughout the audit period. INDIANA STATE BOARD OF ACCOUNTS 20 ALLEN 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). . . ." 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 implemented as designed, and employees lacked sufficient training to carry out suspension and debarment procedures required to certify vendor status. Effect Without the proper implementation of an effectively designed system of internal controls, the system was incapable of effectively preventing, or detecting and correcting, material noncompliance. As a result, the County was not able to provide documentation that the suspension and debarment requirements were followed for two vendors to whom payment was equal to or in excess of $25,000 was made. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a system of internal controls to ensure compliance with the grant agreements and the Procurement and Suspension and Debarment compliance requirement. Additionally, the County should ensure that all necessary personnel understand and follow the compliance requirements and County policies. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2025-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Summary of Finding: Suspension and Debarment – Allen County did not have documentation that vendors’ suspension and debarment status were verified through either a) checking the Excluded Parties List System (EPLS), b) collecting a certification, or c) adding a clause or condition to the covered transaction agreement. Contact Person Responsible for Corrective Action: Chris Cloud, Chief of Staff Contact Phone Number and Email Address: 260-449-4752 / chris.cloud@allencounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct Finding 2025-003, the Chief of Staff to the Board of Commissioners will send an email to all county departments involved in spending SLFRF money to request that they notify the Chief of Staff prior to engaging in a Covered Transaction with a new vendor so that a check of the EPLS can occur before the expense occurs/transaction is undertaken. Chief of Staff will document the search and provide approval/denial to the department desiring to engage in a Covered Transaction. Anticipated Completion Date: This CAP will be completed by September 25, 2026

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $12.65M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $3.51M
93.563 CHILD SUPPORT SERVICES $2.52M
16.575 CRIME VICTIM ASSISTANCE $383,712
16.922 EQUITABLE SHARING PROGRAM $149,766
10.555 NATIONAL SCHOOL LUNCH PROGRAM $124,877
97.067 HOMELAND SECURITY GRANT PROGRAM $102,552
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $93,157
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $89,828
16.588 VIOLENCE AGAINST WOMEN FORMULA GRANTS $72,398
10.553 SCHOOL BREAKFAST PROGRAM $65,088
93.658 FOSTER CARE TITLE IV-E $29,427
16.606 STATE CRIMINAL ALIEN ASSISTANCE PROGRAM $28,284
20.608 MINIMUM PENALTIES FOR REPEAT OFFENDERS FOR DRIVING WHILE INTOXICATED $6,996
93.586 STATE COURT IMPROVEMENT PROGRAM $5,000