FAC Explorer

Finding 498144 (2023-004)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-25
Audit: 320852
Organization: Florence County (WI)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: The County failed to check if vendors were suspended or debarred before contracts over $25,000, violating federal regulations.
  • Impacted Requirements: Non-compliance with 2 CFR Section 200.214 and 200.303 regarding vendor verification and internal controls.
  • Recommended Follow-Up: Use sam.gov or the ELPS listing to verify vendor status annually or before transactions, ensuring compliance with federal guidelines.

Finding Text

2023-004 Federal Grants Management - Procurement Policy Federal Agency: Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: N/A Pass-Through Agency: N/A Award Period: March 1, 2021 – December 31, 2024 Type of Finding: Significant deficiency in internal control over compliance, other matters. Criteria or Specific Requirement 2 CFR Section 200.214 requires non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. 2 CFR 200.303 states “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). Condition The County did not perform a search for suspension and debarment for vendors the County initiated procurement transactions in excess of $25,000. Questioned Costs None Section III – Findings and Questioned Costs – Major Federal and State Programs (Continued) 2023-004 (Continued) Context There was one transaction that exceeded the $25,000 covered transaction threshold during the granting period. During our testing, it was noted on the item tested that Florence County was not reviewing vendors prior to entering into a contract with a vendor to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration. Cause The County was not aware of the requirements under suspension and debarment. Effect The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation We recommend the County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Actions There is no disagreement with the audit finding.

Corrective Action Plan

2023-004 Federal Grants Management – Procurement Policy Recommendation: We recommend County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with the Uniform Guidance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Train staff on 1. Sam.gov and ELPS sites 2. Collecting a certification from entity (SBA Form 1624, Certification Regarding Debarment, Suspension, Ineligibility and Voluntary Exclusion Lower Tier Covered Transactions) 3. Adding a clause or condition to the covered transaction with entity (2 CFR section 180.300) Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager Planned completion date for corrective action plan: Staff Training – November 2024

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 498136 2023-003
    Significant Deficiency
  • 498137 2023-003
    Significant Deficiency
  • 498138 2023-003
    Significant Deficiency
  • 498139 2023-003
    Significant Deficiency
  • 498140 2023-003
    Significant Deficiency
  • 498141 2023-003
    Significant Deficiency
  • 498142 2023-003
    Significant Deficiency
  • 498143 2023-003
    Significant Deficiency
  • 498145 2023-004
    Significant Deficiency Repeat
  • 498146 2023-004
    Significant Deficiency Repeat
  • 498147 2023-004
    Significant Deficiency Repeat
  • 1074578 2023-003
    Significant Deficiency
  • 1074579 2023-003
    Significant Deficiency
  • 1074580 2023-003
    Significant Deficiency
  • 1074581 2023-003
    Significant Deficiency
  • 1074582 2023-003
    Significant Deficiency
  • 1074583 2023-003
    Significant Deficiency
  • 1074584 2023-003
    Significant Deficiency
  • 1074585 2023-003
    Significant Deficiency
  • 1074586 2023-004
    Significant Deficiency Repeat
  • 1074587 2023-004
    Significant Deficiency Repeat
  • 1074588 2023-004
    Significant Deficiency Repeat
  • 1074589 2023-004
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
21.032 Local Assistance and Tribal Consistency Fund $262,776
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $53,000
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $43,230
93.778 Medical Assistance Program $33,336
93.556 Promoting Safe and Stable Families $33,310
93.069 Public Health Emergency Preparedness $33,099
21.027 Coronavirus State and Local Fiscal Recovery Funds $31,848
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $27,989
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $25,923
20.219 Recreational Trails Program $23,830
97.042 Emergency Management Performance Grants $22,063
93.958 Block Grants for Community Mental Health Services $19,781
84.181 Special Education-Grants for Infants and Families $12,075
93.658 Foster Care_title IV-E $11,775
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $11,636
97.024 Emergency Food and Shelter National Board Program $11,584
93.052 National Family Caregiver Support, Title Iii, Part E $10,000
93.053 Nutrition Services Incentive Program $8,111
93.558 Temporary Assistance for Needy Families $7,860
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $6,809
16.710 Public Safety Partnership and Community Policing Grants $6,394
20.600 State and Community Highway Safety $6,346
93.994 Maternal and Child Health Services Block Grant to the States $5,716
93.991 Preventive Health and Health Services Block Grant $4,444
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $4,348
93.324 State Health Insurance Assistance Program $4,330
93.268 Immunization Cooperative Agreements $3,121
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $2,418
93.767 Children's Health Insurance Program $2,067
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $1,980
93.667 Social Services Block Grant $1,924
93.959 Block Grants for Prevention and Treatment of Substance Abuse $1,819
93.575 Child Care and Development Block Grant $1,250
93.071 Medicare Enrollment Assistance Program $833
93.645 Stephanie Tubbs Jones Child Welfare Services Program $722
93.563 Child Support Enforcement $-5,001