Finding 21852 (2022-001)

2022-001 The County?s internal controls within the Department of Public Health were inadequate for ensuring compliance with federal reporting requirements. Assistance Listing Number and Title: 93.495 ? COVID-19 Community Health Workers for Public Health Response and Resilient Federal Grantor Name: U.S. Department of Health and Human Services Federal Award/Contract Number: NU58DP007045 Pass-through Entity Name: N/A Pass-through Award/Contract Number: N/A Questioned Cost Amount: $0 Prior Year Audit Finding: N/A Description of Condition The purpose of the Community Health Worker for Public Health Response and Resilient program is to increase community health worker activities across the nation. Specifically, the program focuses on increasing efforts related to public health response in communities hit hardest by an outbreak and among priority populations that are at high risk for exposure, infection and poorer health outcomes. In 2022, the County spent $1,287,363 in program funds. Of this amount, the County paid $1,059,922 to five subrecipients. The County entered into one subaward with a subrecipient in 2022. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients that make first-tier subawards of $30,000 or more to report them in the FFATA Subaward Reporting System (FSRS). The County must report subawards by the end of the month following the month in which it made the subaward or subaward amendment. We found the County?s internal controls were ineffective for ensuring it reported the one subaward obligated in 2022 in the FSRS, as federal regulations require. We consider this deficiency in internal controls to be a material weakness that led to material noncompliance. Cause of Condition Program staff said they did not know about the FFATA reporting requirements. Effect of Condition Failing to submit the required reports diminishes the federal government?s ability to ensure accountability and transparency of federal spending. Below is a table summarizing the missing report we identified. See Schedule of Findings and Questioned Costs for chart/table. Recommendation We recommend the County strengthen its internal controls to ensure it reports subaward information through the FSRS by the due date, as federal law requires. County?s Response The County agrees with the finding that DPH did not submit a FFATA report through the FSRS portal for one subaward. Public Health Finance will provide continuous training to ensure that personnel are aware of FFATA reporting requirements. Additionally, Public Health Finance will provide management reviews through quarterly monitoring to ensure reporting requirements and deadlines are met. Auditor?s Remarks We appreciate the County?s commitment to resolve this finding and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303 Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, establishes the Federal Funding Accountability and Transparency Act (FFATA) requirements of reporting the subaward information through the FFATA Subaward Reporting System (FSRS).