JEFFERSON, COUNTY OF

Uniform Guidance Policies 2 CFR 200.303 on internal controls states the non-Federal entity must, in part, 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 and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The District has not established effective internal control over federal payroll expenditures to ensure charges were made to the proper funds. This has resulted in various issues in compliance related to Allowable Costs and Costs Principles and Reporting and is due to a lack of reviewing established policies. Failure to establish effective internal controls over federal expenditures could result in federal questioned costs and a lack of funding, along with a modified federal opinion. The District should develop and implement internal control procedures that may help ensure federal awards are properly managed in accordance with the Uniform Guidance.

2 CFR Section 200.302 states, in part, that the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. In addition, the financial management system of each non-Federal entity must provide for certain requirements as stipulated in 2 CFR ??200.334, 200.335, 200.336, and 200.337. The District's accounting ledgers lacked the ability to permit the preparation of reports to be used for to meeting Grants Management Information System (GMIS) reporting requirements. This lead to discrepancies in the amounts reported in GMIS as compared to amounts recorded in the accounting system. In addition, the accounting system lacked the ability to produce a fund report that would report beginning balance, receipts, expenditures, and ending fund balance at any given point in time and to generate a comparison of expenditures with budget amounts for federal programs. The lack of these capabilities does not promote the ability to effectively monitor grant activity and may lead to over spending, which could result in federal questioned costs. The District should review the requirements regarding a financial management system and implement the necessary changes to help ensure compliance.

The Ohio Department of Health Grants Administration Policies and Procedures Manual (OGAAP) Section E 2.1 states that subrecipients are required to submit performance reports to ODH on the project activities of each grant. Program reports are required to be submitted monthly, quarterly, or as indicated in the Solicitation by the ODH program. If the Solicitation requires a monthly Program Reports, it must be completed and submitted via GMIS by the 10th of each month. Monthly Program Reports were required for Covid-19 Contract Tracing (CT20) and Covid-19 Coronavirus Response Supplemental (CO21) grants. Due to a lack of internal controls over the reporting cycle, the reports were not always filed by the required date. Program Reporting Month Due Date Date Filed CT20 January 2021 February 10, 2021 April 27, 2021 February 2021 March 10, 2021 May 5, 2021 March 2021 April 10, 2021 May 6, 2021 April 2021 May 10, 2021 May 11, 2021 June 2021 July 10, 2021 August 2, 2021 July 2021 August 10, 2021 January 24, 2022 August 2021 September 10, 2021 January 24, 2022 September 2021 October 10, 2021 January 24, 2022 October 2021 November 10, 2021 January 24, 2022 November 2021 December 10, 2021 January 24, 2022 December 2021 January 10, 2022 January 24, 2022 Section E 2.2 states that subrecipient monthly or quarterly expenditure reports must be completed and submitted via GMIS within 10 calendar days following the end of the reporting period which is designated in the Solicitation. These reports provide details on the funds received, disbursed, or obligated. Subrecipient monthly or quarterly expenditure reports must be completed and submitted via GMIS by the 10th of each month. The monthly or quarterly report must be based on the subrecipient's accounting records and supporting documentation. The reporting of expenditures and revenues must be on the cash basis; thereby reporting actual expenses paid during the month or quarter. The CT20 monthly reports were not filed by the required date. In addition, there were two expenditures totaling $459 that were reported in GMIS twice. The amounts reported in GMIS also did not agree to the District's accounting records. The monthly reports were not always filed by the required date. In addition, the amounts reported in GMIS did not agree to the District's accounting records. Errors are as follows: Program Reporting Month Due Date Date Filed CT20 January February 10, 2021 June 10, 2021 February March 10, 2021 July 9, 2021 March April 10, 2021 August 2, 2021 April May 10, 2021 August 9, 2021 May June 10, 2021 September 9, 2021 June July 10, 2021 October 12, 2021 September October 10, 2021 January 24, 2022 November December 10, 2021 January 24, 2022 Program Reporting Month Due Date Date Filed CO21 January 2021 February 10, 2021 November 1, 2021 February 2021 March 10, 2021 November 1, 2021 March 2021 April 10, 2021 November 1, 2021 April 2021 May 10, 2021 November 1, 2021 May 2021 June 10, 2021 November 1, 2021 June 2021 July 10, 2021 November 1, 2021 July 2021 August 10, 2021 November 1, 2021 August 2021 September 10, 2021 November 1, 2021 September October 10, 2021 November 1, 2021 December 2021 January 10, 2022 February 18, 2022 Program Reporting Month Due Date Date Filed RC21 January 2021 February 10, 2021 June 23, 2021 February 2021 March 10, 2021 August 26, 2021 March 2021 April 10, 2021 August 26, 2021 April 2021 May 10, 2021 September 8, 2021 May 2021 June 10, 2021 September 21, 2021 June 2021 July 10, 2021 October 1, 2021 July 2021 August 10, 2021 October 7, 2021 September 2021 October 10, 2021 January 26, 2022 October 2021 November 10, 2021 February 1, 2022 November 2021 December 10, 2021 February 2, 2022 December 2021 January 10, 2022 February 8, 2022 Program Expenditure Category GMIS Expenditures District Ledger Expenditures Variance CT20 Payroll $44,237 $45,874 $1,637 CT20 Non Payroll 12,019 6,108 5,911 CO21 Payroll 295,747 281,041 14,706 CO21 Non Payroll 93,728 95,917 2,189 The variances were determined to be due to prior year expenditures being recorded in GMIS in the current year due, movement of expenditures between programs where the expenditures were moved in GMIS and not in the District's ledgers, and general errors in reporting. Errors occurred due to a lack of controls in place over their reporting cycle. Section E 2.1 states the subrecipient Final Expense Report (FER) and any overpayments must be submitted to ODH within thirty-five (35) calendar days following the end of the grant year. The Subrecipient Final Expense Report details the total expenditures for the project period. The FER for the CO21 and RC21 grants were not filed by the required date as denoted below. Program Due Date Date Filed CO21 February 25, 2022 April 25, 2022 RC21 February 25, 2022 April 12, 2022 The District should implement procedures over federal reporting to help ensure all federal reporting requirements are met.

GSA_MIGRATION