Finding 966192 (2023-003)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 300633
Organization: County of Ventura (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to include required information in subrecipient agreements and did not assess the risk of noncompliance for subrecipients.
  • Impacted Requirements: Noncompliance with 2 CFR sections 200.332(a) and 200.332(b) regarding subrecipient monitoring and documentation.
  • Recommended Follow-Up: Ensure all necessary award information is communicated to subrecipients and document risk assessments as per federal guidelines.

Finding Text

2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must 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. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 389741 2023-003
    Significant Deficiency
  • 389742 2023-003
    Significant Deficiency
  • 389743 2023-003
    Significant Deficiency
  • 389744 2023-003
    Significant Deficiency
  • 389745 2023-003
    Significant Deficiency
  • 389746 2023-003
    Significant Deficiency
  • 389747 2023-003
    Significant Deficiency
  • 389748 2023-003
    Significant Deficiency
  • 389749 2023-003
    Significant Deficiency
  • 389750 2023-003
    Significant Deficiency
  • 389751 2023-003
    Significant Deficiency
  • 389752 2023-004
    Material Weakness
  • 389753 2023-004
    Material Weakness
  • 389754 2023-004
    Material Weakness
  • 389755 2023-004
    Material Weakness
  • 389756 2023-004
    Material Weakness
  • 389757 2023-004
    Material Weakness
  • 389758 2023-004
    Material Weakness
  • 966183 2023-003
    Significant Deficiency
  • 966184 2023-003
    Significant Deficiency
  • 966185 2023-003
    Significant Deficiency
  • 966186 2023-003
    Significant Deficiency
  • 966187 2023-003
    Significant Deficiency
  • 966188 2023-003
    Significant Deficiency
  • 966189 2023-003
    Significant Deficiency
  • 966190 2023-003
    Significant Deficiency
  • 966191 2023-003
    Significant Deficiency
  • 966193 2023-003
    Significant Deficiency
  • 966194 2023-004
    Material Weakness
  • 966195 2023-004
    Material Weakness
  • 966196 2023-004
    Material Weakness
  • 966197 2023-004
    Material Weakness
  • 966198 2023-004
    Material Weakness
  • 966199 2023-004
    Material Weakness
  • 966200 2023-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $162.28M
93.563 Child Support Enforcement $14.48M
93.659 Adoption Assistance $12.42M
93.090 Guardianship Assistance $2.67M
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $1.75M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $1.65M
93.556 Promoting Safe and Stable Families $1.44M
16.606 State Criminal Alien Assistance Program $1.15M
97.036 Covid-19 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.10M
97.067 Homeland Security Grant Program $932,671
93.959 Block Grants for Prevention and Treatment of Substance Abuse $920,974
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $882,753
93.958 Block Grants for Community Mental Health Services $789,937
17.270 Reintegration of Ex-Offenders $731,726
93.658 Foster Care_title IV-E $720,605
93.667 Social Services Block Grant $599,398
20.205 Highway Planning and Construction $572,424
14.218 Covid-19 Community Development Block Grants/entitlement Grants $565,801
93.224 Covid-19 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $559,076
16.321 Antiterrorism Emergency Reserve $474,000
14.241 Housing Opportunities for Persons with Aids $424,871
93.052 National Family Caregiver Support, Title Iii, Part E $424,262
93.268 Covid-19 Immunization Cooperative Agreements $419,698
93.994 Maternal and Child Health Services Block Grant to the States $413,165
14.267 Continuum of Care Program $373,111
93.645 Stephanie Tubbs Jones Child Welfare Services Program $336,741
17.259 Wia Youth Activities $324,159
93.889 National Bioterrorism Hospital Preparedness Program $273,122
17.278 Wia Dislocated Worker Formula Grants $260,158
16.741 Dna Backlog Reduction Program $257,162
93.558 Temporary Assistance for Needy Families $252,064
93.044 Covid-19 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $246,983
20.106 Airport Improvement Program $241,414
93.498 Covid-19 Provider Relief Fund $228,271
10.025 Plant and Animal Disease, Pest Control, and Animal Care $200,951
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $190,841
93.053 Nutrition Services Incentive Program $177,299
93.977 Cdc's Collaboration with Academia to Strengthen Public Health $177,086
14.231 Emergency Solutions Grant Program $171,536
93.268 Immunization Cooperative Agreements $165,572
14.231 Covid-19 Emergency Solutions Grant Program $156,533
93.470 Alzheimer's Disease Program Initiative (adpi) $151,621
20.106 Covid-19 Airport Improvement Program $148,000
16.320 Services for Trafficking Victims $147,663
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $138,365
93.778 Medical Assistance Program $138,266
14.239 Home Investment Partnerships Program $137,644
10.904 Watershed Protection and Flood Prevention $136,354
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $131,167
16.575 Crime Victim Assistance $130,307
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $127,827
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $125,858
93.150 Projects for Assistance in Transition From Homelessness (path) $113,072
93.566 Refugee and Entrant Assistance_state Administered Programs $112,403
21.023 Covid-19 Emergency Rental Assistance Program $110,541
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $107,445
16.753 Congressionally Recommended Awards $104,331
16.833 National Sexual Assault Kit Initiative $90,347
10.555 National School Lunch Program $85,039
17.277 Covid-19 Workforce Investment Act (wia) National Emergency Grants $78,804
93.917 Hiv Care Formula Grants $78,205
20.507 Federal Transit_formula Grants $76,130
97.044 Assistance to Firefighters Grant $74,097
16.838 Comprehensive Opioid Abuse Site-Based Program $71,972
17.258 Wia Adult Program $64,672
93.071 Medicare Enrollment Assistance Program $60,000
10.704 Law Enforcement Agreements $57,892
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $57,532
20.616 National Priority Safety Programs $55,684
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $52,377
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $52,083
16.922 Equitable Sharing Program $51,022
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $50,332
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $48,657
10.553 School Breakfast Program $44,525
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $44,154
10.665 Schools and Roads - Grants to States $44,039
93.045 Covid-19 Special Programs for the Aging_title Iii, Part C_nutrition Services $43,668
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $38,478
16.U01 Eradication Suppression Fy 2022 Dea Domestic Cannabis Eradication Suppression Program $33,722
93.967 Cdc's Collaboration with Academia to Strengthen Public Health $32,930
16.607 Bulletproof Vest Partnership Program $31,474
17.277 Workforce Investment Act (wia) National Emergency Grants $30,628
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $30,331
14.218 Community Development Block Grants/entitlement Grants $30,000
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $29,566
97.042 Emergency Management Performance Grants $25,944
93.069 Public Health Emergency Preparedness $25,741
93.626 Covid-19 Affordable Care Act State Health Insurance Assistance Program (ship) and Aging and Disability Resource Center (adrc) Options Counseling for Medicare-Medicaid Individuals in States with Approved Financial Alignment Models $23,349
16.710 Public Safety Partnership and Community Policing Grants $19,349
17.235 Senior Community Service Employment Program $17,564
16.738 Edward Byrne Memorial Justice Assistance Grant Program $11,138
93.048 Special Programs for the Aging_title Iv_and Title Ii_discretionary Projects $10,000
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $8,015
15.664 Fish and Wildlife Coordination and Assistance Programs $7,610
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $6,863
21.016 Equitable Sharing $5,828
45.310 Grants to States $5,000
93.747 Covid-19 Elder Abuse Prevention Interventions Program $4,382
15.904 Historic Preservation Fund Grants-in-Aid $4,000
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $3,606
14.228 Covid-19 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $2,874
16.U01 Eradication Suppression Fy 2023 Dea Domestic Cannabis Eradication Suppression Program $1,824
93.324 State Health Insurance Assistance Program $750
20.600 State and Community Highway Safety $90