Finding 12518 (2022-004)

Finding 2022-004 ? Reporting Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed Through: State of California, Department of Public Health (CDPH) Award Year: Fiscal Year 2021-2022 Compliance Requirement: Reporting Questioned Costs: $0 Criteria Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) ?200.303 states that the non- Federal entity (County) must establish and maintain effective internal control over the Federal award that 21 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). As a subrecipient of the COVID-19 ELC funding, the Centers for Disease and Control Prevention (CDC) requires timely submission of quarterly progress reports, quarterly expenditure reports, and monthly expenditure reports to the pass-through entity, CDPH. Condition During our testing of compliance with the reporting requirement, we selected two quarterly progress reports, two quarterly expenditure reports, and two monthly reports, and noted that the County did not submit the six required reports on a timely basis. Cause of Condition The County?s existing internal control system is not properly designed to meet the control objectives under reporting requirements. Repeat Finding No. Effect of Condition The County did not comply with ELC reporting requirements. Recommendation We recommend the County design and implement proper internal control activities over the reporting compliance requirement to ensure fiscal accountability and reporting requirements are met in a timely manner. Management Response and Corrective Action Plan The quarterly reports were managed under Department administration resources during the COVID pandemic response. During this time there were significant vacancies with the Department and consistent turnover that required for staff to be constantly retrained in their duties. As Department administration was able to stabilize its resources the analyst compiling the information from multiple divisions still had the challenge of managing the collection of responses with a highly impacted department staff. The department administration analyst leading the compiling of the information for ELC quarterly reports was also assisting with COVID response duties in ensuring contracts and resources were in place to maintain or adjust COVID response resources. In addition, there was significant turnover and addition of staff at the State level that didn?t allow for timely responses to local inquiries that affect contract management and report. After the stabilization of the workforce at both levels there has been significant improvement in meeting timelines.