Jackson County

2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 CFR § 200.302(b)(6) states the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Additionally, for Federal awards, the Uniform Guidance requires a written policy for the procurement requirements outlined in 2 CFR § 200.318(c)(1), 2 CFR § 200.318(c)(2), and 2 CFR § 200.320(B) 2 CFR 200.302(b)(7) requires written procedures for determining the allowability of costs in accordance with Subpart E-Cost Principles of this part and the terms and conditions of the Federal award. 2 CFR 200.430 states that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR 200.431 requires established written leave policies if the entity intends to pay fringe benefits. 2 CFR 200.464(a)(2) requires reimbursement of relocation costs to employees be in accordance with an established written policy must be consistently followed by the employer. 2 CFR 200.475 requires reimbursement and/or charges to be consistent with those normally allowed in like circumstances in the non-Federal entity's non-federally-funded activities and in accordance with non-Federal entity's written travel reimbursement policies. The General Health District did not have written policies as required by Uniform Guidance. The failure to implement written policies as required by Uniform Guidance could result in noncompliance with the District’s federal programs. The General Health District should adopt written policies in accordance with the Uniform Guidance.

2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 CFR § 200.303(a) provides 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. The General Health District has established procedures to approve timesheets by requiring the employee and department supervisor to sign the timesheets indicating they are accurate (employee) and approved (supervisor). For 2024, 11% of payroll disbursement timesheets tested over the Community Health Workers for Public Health Response and Resilient Program were not signed by the Health Commissioner and/or Director of Administration to indicate timesheets were accurate. Failure to follow the approved procedures could result in the occurrence of unallowable payroll transactions. The General Health District should ensure that both the employee and department supervisor sign the timesheets. These approvals should be maintained for audit.

31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds. The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting Section states that all OCJS projects are required to submit Quarterly Subgrant Reports (QSR), which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested. The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month, following quarter end and were not on file for the Retention Incentive Grant for the first and second quarters of 2024. The only QSR was submitted in 2024 for the Retention Incentive grant covered the first 3 quarters of 2024 and it also reported corrections for the 2023 expenditures previously reported, created on October 28, 2024, and then modified on November 27, 2024. Additionally, the quarterly report was not filed for the 1st quarter and Quarterly reports were not submitted timely for Quarters 2 through 4 for the Operation Cleanup Grant. The Sheriff's Department reported both of these grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted a variance between total reported expenditures compared to the county ledgers which resulted in an overstatement of $10,915 in reported expenditures. Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. The Court did not file quarterly reports for Quarters 1 or 2 in 2024 but instead filed only one final report for the period ending September 30, 2024 which was due by October 31, 2024, but filed on December 13, 2024. Failure to submit the required reports timely to the pass-through entity could result in material noncompliance and potential loss of future funding. The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and based on actual information from underlying accounting ledgers.

2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024. The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. Due to the delay of the grant start date, the first payment not made until 2023. During 2024, payments 7 through 10 were made lacking documentation of how the payment amounts were calculated. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations. Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023, and 2024 hourly rate for new employees in 2024. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted that amounts paid to employees from Payment 7 through Payment 10 covering March through October 2024 were not adequately documented as we could not recalculate the bi-monthly payments totaling $13,476.52 in salaries and $2,072 in related benefits though we did note no employee received greater than 10% of their annual salary maximum. Lack of supporting documentation could result in noncompliance and/or questioned costs. The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved. The grant was completed as of December 31, 2024.

Ohio Administrative Code § 5101:9-7-10 (B) states pursuant to 45 C.F.R. part 96, states are required to report services provided by the County Department of Job and Family Services (CDJFS), using federal, state or local social services funds. The CDJFS may provide services through compact services, direct services, purchased services or grant agreements as defined in rule 5101:2-25-02 of the Administrative Code. The purpose of the SSBG quarterly summary reporting system is to collect social services expenditure data by county each quarter in order to complete annual federal reporting as mandated in 42 U.S.C. 1397e. Further, Ohio Administrative Code § 5101:9-7-10 (C) states each CDJFS shall enter required service and expenditure data in the SSBG reporting system no later than the thirtieth day of the month following the last month of the quarter, e.g., October thirtieth for the July through September time period. The CDJFS shall submit a Title XX SSBG quarterly report even if SSBG direct services were not provided or purchased service expenditures were not made during the quarter. During testing of Quarter 2 for 2024, the expenditure data reported by the CDJFS for program code 738 was overstated $38,369 due to the CDJFS using the incorrect total from the CR454A report. This could result in delays in funding from CDJFS draw requests. Job and Family Services Fiscal Staff should review the data prepared for the quarterly reported prior to submission to ensure it does agree back to the underlying ledgers for quarterly expenditures.

Ohio Admin. Code 5101:9-7-20(E) outlines the procedures to be utilized for random moment sampling (RMS) time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services including those administered through the public children services agency. These procedures include an employee completing the required comments section, within WebRMS, with comments that demonstrate that the selected program and activity codes supporting the work performed by the assigned position at the time of the observation and ensuring adequate backup documentation is available to verify the activity being performed. The County Job and Family Services Agency did not ensure supporting source documentation was attached to the RMS observation for 3.3 percent of RMS time studies observations tested. The employees selected for these RMS observations failed to attach support when completing the observation. These time studies are used to allocate expenditures across the federal programs for the county agency and failure to maintain support for these activities could cause incorrect charges to federal programs. The County Job and Family Services Agency should revisit and implement internal control policies and procedures over its Random Moment Sample processes to ensure supporting source documentation is maintained or exists in order to be compliant with Federal laws and regulations.

2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 CFR § 200.302(b)(6) states the financial management system of each non-Federal entity must provide for written procedures to implement the requirements of 2 CFR § 200.305 Payment. Additionally, for Federal awards, the Uniform Guidance requires a written policy for the procurement requirements outlined in 2 CFR § 200.318(c)(1), 2 CFR § 200.318(c)(2), and 2 CFR § 200.320(B) 2 CFR 200.302(b)(7) requires written procedures for determining the allowability of costs in accordance with Subpart E-Cost Principles of this part and the terms and conditions of the Federal award. 2 CFR 200.430 states that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable. 2 CFR 200.431 requires established written leave policies if the entity intends to pay fringe benefits. 2 CFR 200.464(a)(2) requires reimbursement of relocation costs to employees be in accordance with an established written policy must be consistently followed by the employer. 2 CFR 200.475 requires reimbursement and/or charges to be consistent with those normally allowed in like circumstances in the non-Federal entity's non-federally-funded activities and in accordance with non-Federal entity's written travel reimbursement policies. The General Health District did not have written policies as required by Uniform Guidance. The failure to implement written policies as required by Uniform Guidance could result in noncompliance with the District’s federal programs. The General Health District should adopt written policies in accordance with the Uniform Guidance.

2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 C.F.R § 200.303(a) provides 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. The General Health District has established procedures to approve timesheets by requiring the employee and department supervisor to sign the timesheets indicating they are accurate (employee) and approved (supervisor). For 2024, 8% of payroll disbursement timesheets tested over the Community Health Workers for Public Health Response and Resilient Program were not signed by the Health Commissioner and/or Director of Administration to indicate timesheets were accurate. Failure to follow the approved procedures could result in the occurrence of unallowable payroll transactions. The General Health District should ensure that both the employee and department supervisor sign the timesheets. These approvals should be maintained for audit.

2 CFR § 300 codified in 45 CFR part 75 gives regulatory effect to the Department of Health and Human Services. 2 C.F.R § 200.303(a) provides 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. The General Health District established procedures to approve bills at monthly board meetings. The General Health District failed to approve 19% of nonpayroll disbursements tested in 2023 over the Community Health Workers Federal Program. Failure to follow the approved the disbursements could result in the occurrence of unallowable transactions. The General Health District should ensure that they approve all payments via the edit list and/or hand signed list. These approvals should be listed and maintained for audit.

31 C.F.R. § 35.4(c), Reporting and Requests for Other Information, states during the period of performance, recipients shall provide to the Secretary or her delegate, as applicable, periodic reports providing detailed accounting of the uses of funds. The Ohio Department of Public Safety, Office of Criminal Justice Services (OCJS) Standard Federal Subgrant Conditions Handbook, Chapter 4: Corresponding and Reporting, Section: Quarterly Subgrant Reports states that all OCJS projects are required to submit Quarterly Subgrant Reports, which shall be submitted on the last day of the month following the calendar quarter end. Additionally, this Handbook states that a report must be submitted every quarter, even when there have been zero expenditures or if a payment is not being requested. The Sheriff's Department did not have internal control procedures in place regarding Federal grant reporting for the Retention Incentive and Operating Clean Up grants. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 2 or Quarter 4 for the Retention Incentive Grant and were not submitted timely for Quarter 3 or 4 for the Operation Cleanup Grant. Additionally, quarterly reports were not filed for the 1st or 3rd quarter for the Retention Incentive grant or the 2nd quarter for the Operation Cleanup grant. We also noted some quarterly reports were not accepted by the grantor and had to be resubmitted prior to approval. Finally, we noted that once reports were submitted, they could not be modified but due to errors in the reporting of the Retention Incentive Grant, a revision made in 2024 noted corrected amounts for each quarter of 2023. The Sheriff's Department reported both grants in the same county fund even though separate quarterly reports were required. As such, we were unable to determine which grant certain disbursements related to and therefore were unable to determine if individual grant quarterly reports agreed to the underlying ledgers. We did note material differences when comparing the sum of the two grants reported expenditures each quarter to the underlying accounting system. We noted an initial variance between total reported expenditures at year end compared to the county ledgers which resulted in an understatement of $16,693 in reported expenditures. Using the 2023 corrected amounts from the revision filed in 2024 resulted in an overall overstatement of $2,026 of reported amounts when compared to the underlying ledgers. Further, Municipal Court did not have internal control procedures in place regarding Federal grant reporting for the Violence Reduction grant. Quarterly reports were due the last day of the month following quarter end and were not submitted timely for Quarter 5. In addition, material discrepancies were found in the expenditures reported on these reports compared to the underlying accounting system. Quarter 2 was understated $26,783 but then corrected by the Grants Administrator on Quarter 3 filing. In addition, the year-to-date total expenditures reported on Quarter 5 reconciled to the underlying accounting ledgers for the year. Failure to timely submit the required reports to the pass-through entity could result in material noncompliance and potential loss of future funding. The Sheriff and Municipal Court offices' should establish internal control procedures to help ensure all required reports are submitted timely and agree to underlying ledgers.

2 C.F.R. § 1000.10 gives regulatory effect to the Department of the Treasurer for 2 C.F.R. § 200.403(a), which requires that costs be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. 2 C.F.R. § 200.403(c) documents that costs must be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. State ex rel. McClure v. Hagerman, 155 Ohio St. 320 (1951) provides that expenditures made by a governmental unit should serve a public purpose. Typically, the determination of what constitutes a “proper public purpose” rests with the judgment of the governmental entity, unless such determination is arbitrary or unreasonable. Even if a purchase is reasonable, Ohio Attorney General Opinion 82-006 indicates that it must be memorialized by a duly enacted ordinance or resolution and may have a prospective effect only. Auditor of State Bulletin 2003-005 Expenditure of Public Funds/Proper “Public Purpose” states, in part, the Auditor of State’s Office will only question expenditures where the legislative determination of a public purpose is manifestly arbitrary and incorrect. The Sheriff's Department was awarded the American Rescue Plan Funding for the Community Violence Intervention program to offer employee incentive and retention funds of $72,159 on October 14, 2022. The Sheriff's department completed the request for proposal for the grant based on May 2022 wages with an original grant period being April 2022 through April 2024. However, funding wasn't received until April 2023 and the Sheriff's Department received a grant extension through October 2024. The Sheriff's Clerk prepared a spreadsheet to base the retention and incentive payments on 10% of the annual salaries for dispatchers and deputies using their pay rates as of May 2022. This 10% annual amount was then to be paid over 24 months. There were to be bi-monthly payments for the period May 2022 through April 2024 for employee retention of deputies and dispatchers. Due to the delay of the grant start date, the first payment was made in 2023 and was a single payment to cover missed payments from May to December 2022 using the 2022 pay rates noted in the initial grant award calculation. Payment 1 in 2023 was for the four bi-monthly payments missed in 2022 (8 months) and payment 2 was for two bi-monthly payments (4 months) for January to April 2023. After these two payments, the Clerk changed the amounts being paid as the 10% limit would also need to cover the related county paid benefits on these retention and incentive payments which were not previously considered in the 10% maximum calculation. The Clerk recalculated the totals to be paid as salary payments by subtracting the related benefit total from the salary maximum previously calculated and dividing that amount over the remaining payments. She started paying lesser amounts for the subsequent bi-monthly payments, but we could not agree those amounts to support as calculations were not retained. Additionally, when the grant was finally received in 2023, there were employees that had been used in the initial calculation as of May 2022 that were no longer employed by the County. Since those employees did not receive any payments, the Clerk used the funding that was freed up from those employees to add newly hired employees to the retention and incentive payments. There was no supporting documentation on file for how new employees were added to the grant or how the amount allocated for new employees was calculated. While these payments were allowable for the purpose of retention of employees there were not sufficient internal controls in place for the calculation of the payments made over the life of the grant as the calculations changed throughout the year as employees left and were replaced. For most new employees, a bi-monthly flat rate not related to a percentage of their salary was paid. These flat rates were not approved by the Sheriff to be used in place of the 10% annual max calculations. Due to the lack of supporting documentation on file to determine how the Sheriff's Clerk calculated the retention payments to employees, we calculated a maximum of 10% annual salary per employee using 2022 hourly rates for those employed in 2022 and 2023 hourly rates for new employees in 2023. We then divided that amount by 24 months as the one year annual amount was to be paid across two years to get a monthly incentive amount and then multiplied the monthly amount by the number of months actually employed during the grant period. We compared our recalculated amounts to amounts actually paid through the final payment in 2024 to determine if there were any over payments over the life of the grant. We noted two of the twenty-three employees receiving retention and incentive payments in 2023 exceeded the 10% maximum. These employees were overpaid $192.53 and $261.03, respectively including salaries and related benefits. Both of these employees left employment in 2023 so they did not receive any further payments in 2024. These overpayments do not represent a proper public purpose. We further noted that amounts paid to employees from Payment 3 through Payment 6 covering May through December 2023 were not adequately documented as we could not recalculate the bi-monthly payments totaling $15,284 in salaries and $2,773 in related benefits. The Sheriff's office should implement procedures to ensure all supporting documentation for grant payments are maintained. Actual amounts paid by grant funds to employees should be supported by calculations and changes to the calculations should be approved.

31 CFR § 35.4(c) requires, in part, recipients, during the period of performance, to provide the Secretary of the U.S. Department of Treasury periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory's tax revenue sources, and such other information as the Secretary may require for the administration of this section. In the Coronavirus State and Local Fiscal Recovery Funds Final Rule, Treasury stated that it clarified reporting deadlines in their Compliance and Reporting Guidance. Treasury’s Compliance and Reporting guidance states that metropolitan cities and counties with a population below 250,000 residents that are allocated less than $10 million in SLFRF funding and non-entitlement units that are allocated less than $10 million in SLFRF funding are required to submit annual Project and Expenditure Reports. It further states that the initial Project and Expenditure Report covering March 3, 2021 to March 31, 2022 was required to be submitted to Treasury by April 30, 2022, and subsequent annual reports will cover one calendar year and must be submitted to Treasury by April 30. The County was required to summit a Project and Expenditure Report by April 30, 2023, to the U.S. Department of the Treasury through the Treasury’s Portal. The County submitted the required Project and Expenditure Report, however, the County 2023 revenue loss current period obligations were overstated by $1,431,250, current period expenditures were over stated by $2,023,063, and cumulative expenditures were over stated by $2,017,832. Failure to have proper controls in place to ensure the timely and accurate submission of the Project and Expenditure Reports could result in Treasury taking action against the County for failure to comply with programmatic requirements. The County should implement controls to ensure the Project and Expenditure Report is accurate, supporting by appropriate documentation, and filed by the required due date.

2 CFR ? 200.305 provides that grantees and subgrantees shall be paid in advance, provided they maintain or demonstrate the willingness and ability to maintain procedures to minimize the time elapsing between the transfer of the funds and their disbursement by the grantee or subgrantee. Ohio Development Services Agency, Office of Community Development (OCD), Grant Operations and Financial Management Policy and Procedures Program Policy Notice: OCD 15-06 required grantees to develop a cash management system to minimize the time elapsed between the funds transferred from OCD and funds disbursed by the grantee, in compliance with 2 CFR ? 200.305 - Payment. Implementing the cash management system shall ensure disbursed OCD funds-on-hand balance is less than $5,000 within 30 days of receiving the funds. Lump sum drawdowns are not permitted. In 2020, drawdowns were made, but the disbursements made within the required time period of receipt did not bring the balance on hand to a balance of less than $5,000 for 44% percent of drawdowns. The following funds were drawn down but were not disbursed to a balance of less than $5,000 within thirty days of receipt: From Grant B-F-17-1BK-1 Community Development Block Grant - Draw of $167,067 was received by the County on February 21, 2020 however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until March 24, 2020 or 32 days. From Grant B-C-18-1BK-1 Community Development Block Grant - Draw of $16,345 was received by the County on December 20, 2019 however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until January 28, 2020 or 39 days. - Draw of $10,975 was received by the County on January 24, 2020, however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until February 25, 2020 or 32 days. - Draw of $24,155 was received by the County on April 17, 2020, however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until August 11, 2020 or 116 days. - Draw of $38,045 was received by the County on October 19, 2020, however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 through December 31, 2020 or 73 days. From Grant B-F-19-1BK-1 Community Development Block Grant - Draw of $40,000 was received by the County on April 16, 2020 however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until July 9, 2020 or 84 days. From Grant B-X-19-1BK-1 Community Development Block Grant - Draw of $11,000 was received by the County on April 16, 2020 however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until July 29, 2020 or 104 days. Based on our testing, utilizing the 2% average 2020 U.S. Treasury Current Value of Funds Rate, we estimate the imputed interest could have been $292 for the year ended December 31, 2020. The County should monitor the cash balances in these funds to determine when and how much cash to request. This will help to ensure the monies drawn down are expended within the required time frame.

2 CFR ? 200.305 provides that grantees and subgrantees shall be paid in advance, provided they maintain or demonstrate the willingness and ability to maintain procedures to minimize the time elapsing between the transfer of the funds and their disbursement by the grantee or subgrantee. Ohio Development Services Agency, Office of Community Development (OCD), Grant Operations and Financial Management Policy and Procedures Program Policy Notice: OCD 15-06 required grantees to develop a cash management system to minimize the time elapsed between the funds transferred from OCD and funds disbursed by the grantee, in compliance with 2 CFR ? 200.305 - Payment. Implementing the cash management system shall ensure disbursed OCD funds-on-hand balance is less than $5,000 within 30 days of receiving the funds. Lump sum drawdowns are not permitted. In 2019, drawdowns were made, but the disbursements made within the required time period of receipt did not bring the balance on hand to a balance of less than $5,000 for 18% percent of drawdowns. The following funds were drawn down but were not disbursed to a balance of less than $5,000 within thirty days of receipt: From Grant B-C-18-1BK-1 Community Development Block Grant ? Draw of $55,535 was received by the County on July 9, 2019, however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until August 21, 2019 or 43 days. ? Draw of $37,870 was received by the County on July 21, 2019, however, the money was not expended within thirty days of receipt as required, and the balance exceeded $5,000 until October 2, 2019 or 73 days. Based on our testing, utilizing the 1% average 2019 U.S. Treasury Current Value of Funds Rate, we estimate the imputed interest could have been $46 for the year ended December 31, 2019. The County should monitor the cash balances in these funds to determine when and how much cash to request. This will help to ensure the monies drawn down are expended within the required time frame.

GSA_MIGRATION

GSA_MIGRATION

GSA_MIGRATION