Finding 624102 (2022-003)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-09-10
Audit: 51115
Organization: Oconto County, Wisconsin (WI)

AI Summary

  • Core Issue: The County lacks procedures to verify that contractors are not suspended or debarred, violating federal compliance requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200, which prohibits contracting with suspended or debarred entities in covered transactions.
  • Recommended Follow-Up: Update procurement policies to include suspension and debarment verification to ensure compliance with federal regulations.

Finding Text

2022-003 Suspension & Debarment Federal Agency: U.S. Department of Health and Human Services/U.S. Department of Treasury Federal Program Names: COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 93.323 and 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155802 and 155811 Federal Award Identification Number and Year: NU50CK000534 and SLFRP0756; 2020 Award Periods: October 1, 2020 ? October 31, 2022 and March 1, 2020 ? December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal 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. Condition: The County does not have established procedures to meet the compliance requirement for suspension & debarment. Questioned Costs: None. Context: While performing compliance procedures, it was noted that the County does not have established policies regarding suspension and debarment and procedures to verify were not completed. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not include a clause about suspension and debarment verification to establish procedures. Effect: The County is not in compliance with suspension and debarment requirements. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Official: There is no disagreement with the finding.

Categories

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

Other Findings in this Audit

  • 47657 2022-003
    Material Weakness
  • 47658 2022-003
    Material Weakness
  • 47659 2022-002
    Material Weakness
  • 47660 2022-003
    Material Weakness
  • 624099 2022-003
    Material Weakness
  • 624100 2022-003
    Material Weakness
  • 624101 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $610,580
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $297,610
93.778 Medical Assistance Program $293,129
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $142,023
93.667 Social Services Block Grant $116,397
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $100,246
10.912 Environmental Quality Incentives Program $94,638
93.575 Child Care and Development Block Grant $63,589
15.662 Great Lakes Restoration $56,938
97.042 Emergency Management Performance Grants $55,061
84.069 Public Health Emergency Preparedness $51,441
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $47,060
93.268 Immunization Cooperative Agreements $45,214
21.219 Recreational Trails Program $45,000
93.556 Promoting Safe and Stable Families $42,827
66.181 Special Education-Grants for Infants and Families $36,543
15.658 Natural Resource Damage Assessment, Restoration and Implementation $35,270
20.219 Recreational Trails Program $28,100
21.027 Coronavirus State and Local Fiscal Recovery Funds $25,179
93.767 Children's Health Insurance Program $23,509
93.658 Foster Care_title IV-E $21,954
20.469 Great Lakes Program $19,781
93.090 Guardianship Assistance $18,908
21.019 Coronavirus Relief Fund $17,546
93.994 Maternal and Child Health Services Block Grant to the States $13,829
93.958 Block Grants for Community Mental Health Services $13,353
93.959 Block Grants for Prevention and Treatment of Substance Abuse $12,242
93.991 Preventive Health and Health Services Block Grant $6,223
10.561 Special Supplemental Nutrition Program for Women, Infants, and Children $3,758
16.607 Bulletproof Vest Partnership Program $1,958
93.645 Stephanie Tubbs Jones Child Welfare Services Program $1,337
93.659 Adoption Assistance $681
93.558 Temporary Assistance for Needy Families $405
93.563 Child Support Enforcement $-42,590