Finding 401182 (2022-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2024-06-18

AI Summary

  • Core Issue: Walla Walla County failed to monitor its subrecipient for compliance with federal regulations regarding eligibility for the Eviction Rent Assistance Program.
  • Impacted Requirements: The County did not establish adequate internal controls as mandated by federal regulations, leading to material noncompliance.
  • Recommended Follow-Up: The County should enhance its monitoring processes to ensure subrecipients comply with eligibility requirements and consider testing a specific number of beneficiaries for oversight.

Finding Text

Walla Walla County January 1, 2022 through December 31, 2022 2022-001       The County had inadequate controls for ensuring compliance with federal subrecipient monitoring requirements. Assistance Listing Number and Title: 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of Treasury Federal Award/Contract Number: 1505-0271 Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: 21-4619C-129   Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-005       Description of Condition The purpose of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to provide direct payment to states, U.S. territories, tribal governments, metropolitan cities, counties and non-entitlement units of local government through states. The County received an award from the Washington State Department of Commerce for its Eviction Rent Assistance Program (ERAP) 2.0, funded by SLFRF. ERAP is intended to prevent evictions that would contribute to the spread of COVID-19 by paying past due, current due and future rent to those with the greatest needs while distributing funds equitably. During fiscal year 2022, the County spent $6,534,010 of its ERAP award from Commerce. Of this amount, the County passed through $2,854,117 to one subrecipient to administer the program. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. When the County passes federal funding onto subrecipients, federal regulations require the County to monitor subrecipients to ensure they comply with the terms and conditions of the federal award. For awards dependent on household eligibility, monitoring would include verifying the subrecipients only assisted households that met program eligibility requirements. The amount of verification would depend on each subrecipient’s noncompliance risk. Our audit found the County did not monitor its subrecipient as federal regulations require. Specifically, the County did not obtain documentation from the subrecipient to ensure the assisted households were eligible. We consider this internal controls deficiency to be a material weakness that led to material noncompliance. Cause of Condition After receiving the finding in the prior audit, the County began changing its controls. However, monitoring was not performed to ensure assisted households were eligible and thus the County did not comply with federal regulations. Effect of Condition The County did not monitor the subrecipient to ensure it complied with the terms and conditions of the subaward and appropriately used federal program funds. Since the County did not monitor its subrecipient, it was unable to confirm only eligible households received assistance. Recommendation We recommend the County monitor its subrecipients to ensure they comply with the terms and conditions of their federal subawards, including providing funds only to eligible program households. County’s Response We appreciate the auditor's assessment, analysis, and recommendations.  However, we disagree with the conclusion reached and the finding.  The auditor, during oral conversation discussing context, indicated the quantity of program beneficiaries reviewed for eligibility did not reach the auditor's expected quantity for adequate monitoring.  As a management team, we assessed risk and determined the level of appropriate monitoring to consist of: 1) financial monitoring through review of reimbursement requests, which contained eligibility information necessary for oversight; 2) execution of regularly scheduled status and reporting meetings wherein we obtained ongoing programmatic data; and 3) review of audit reports, where applicable.  We note neither our award agreement nor applicable federal regulations require a specific quantity of files to be reviewed as part of subrecipient monitoring.  Accordingly, we do not concur with the presence of a finding.  In addition, no instances of ineligible beneficiaries were identified by the auditor such that a material weakness classification does not appear reasonable or appropriate.   That being said, we will assess our procedures and add greater clarity to help better tell this story going forward.  We will also consider whether testing a specific number of beneficiaries is necessary and may be conducted efficiently.  Auditor’s Remarks We reaffirm our audit finding. Our work is performed in accordance with federal regulations and governmental auditing standards. We will review the correction action taken during our next regular 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. Title 2 CFR Part 200, Uniform Guidance, section 332, Requirements for pass through entities, establishes the requirements for subrecipient monitoring and management requirements for pass-through entities. 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.

Corrective Action Plan

We appreciate the auditor's assessment, analysis, and recommendations. However, we disagree with the conclusion reached and the finding. The auditor, during oral conversation discussing context, indicated the quantity of program beneficiaries reviewed for eligibility did not reach the auditor's expected quantity for adequate monitoring. As a management team, we assessed risk and determined the level of appropriate monitoring to consist of: 1) financial monitoring through review of reimbursement requests, which contained eligibility information necessary for oversight; 2) execution of regularly scheduled status and reporting meetings wherein we obtained ongoing programmatic data; and 3) review of audit reports, where applicable. We note neither our award agreement nor applicable federal regulations require a specific quantity of files to be reviewed as part of subrecipient monitoring. Accordingly, we do not concur with the presence of a finding. In addition, no instances of ineligible beneficiaries were identified by the auditor such that a material weakness classification does not appear reasonable or appropriate. That being said, we will assess our procedures and add greater clarity to help better tell this story going forward. We will also consider whether testing a specific number of beneficiaries is necessary and may be conducted efficiently.

Categories

Subrecipient Monitoring Eligibility

Other Findings in this Audit

  • 401183 2022-001
    Material Weakness Repeat
  • 401184 2022-002
    Material Weakness Repeat
  • 401185 2022-002
    Material Weakness Repeat
  • 977624 2022-001
    Material Weakness Repeat
  • 977625 2022-001
    Material Weakness Repeat
  • 977626 2022-002
    Material Weakness Repeat
  • 977627 2022-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 Covid 19 - Coronavirus State and Local Fiscal Recovery Funds $2.94M
14.231 Covid 19 - Emergency Solutions Grant Program $366,567
93.268 Covid 19 - Immunization Cooperative Agreements $345,483
93.778 Medical Assistance Program $138,405
93.323 Covid 19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $114,928
93.959 Block Grants for Prevention and Treatment of Substance Abuse $84,355
93.563 Child Support Services $80,186
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $79,578
16.575 Crime Victim Assistance $67,115
93.069 Public Health Emergency Preparedness $51,529
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $23,732
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $20,724
93.421 Covid 19 - Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation?s Health $19,717
14.267 Continuum of Care Program $19,449
93.268 Immunization Cooperative Agreements $19,259
93.994 Maternal and Child Health Services Block Grant to the States $18,130
97.012 Boating Safety Financial Assistance $16,134
16.588 Violence Against Women Formula Grants $15,851
97.042 Covid 19 - Emergency Management Performance Grants $14,205
97.067 Homeland Security Grant Program $12,636
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children $11,939
97.042 Emergency Management Performance Grants $11,287
97.039 Hazard Mitigation Grant $10,280
93.387 National and State Tobacco Control Program $9,322
16.738 Edward Byrne Memorial Justice Assistance Grant Program $4,798
20.205 Highway Planning and Construction $2,805
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $2,779
93.658 Foster Care Title IV-E $1,176
20.616 National Priority Safety Programs $628
10.572 Wic Farmers' Market Nutrition Program (fmnp) $212