Tuscarawas County Health DepartmentLocal Government

2 C.F.R. § 417.10 gives regulatory effect, as supplemented, to the United States Department of Agriculture for 2 C.F.R. 180. 2 C.F.R. § 180.305 states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 CFR § 180.135. 2 C.F.R. § 180.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 C.F.R. § 180.220. All nonprocurement transactions as defined in 2 C.F.R. § 180.970 (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 C.F.R. § 180.215. When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov/content/home); collecting a certification from the entity or adding a clause or condition to the covered transactions with that entity. The Tuscarawas County Metropolitan Sewer District did not have the proper internal controls in place to verify that all entities, with whom the Tuscarawas County Metropolitan Sewer District had entered into covered transactions, had not been suspended or debarred. During testing of procurement, suspension and debarment controls and compliance requirements for the Water and Waste Disposal Systems for Rural Communities AL #10.760, we noted one instance where the County had payments to a vendor of more than $25,000 and there was no evidence the Tuscarawas County Metropolitan Sewer District checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for one of the two contracts with covered transaction in the Water and Waste Disposal Systems for Rural Communities AL#10.760 during Fiscal Year 2024. Failing to implement appropriate controls may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

2 C.F.R. § 376.10 gives regulatory effect to the Department of Health and Human Services for 2 C.F.R. Part 180. 2 C.F.R. 180.305 states that Non-Federal entities are prohibited from entering into a covered transaction with parties that are suspended or debarred or whose principals are suspended or debarred, unless the Federal agency responsible for the transaction grants an exception under 2 C.F.R. § 180.135. 2 C.F.R. 180.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. Procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) are covered transactions if the contracts are expected to equal or exceed $25,000 or meet certain other specified criteria outlined in 2 C.F.R. § 180.220. All nonprocurement transactions as defined in 2 C.F.R. § 180.970 (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless exempt by 2 C.F.R. § 180.215. When a non-Federal entity enters into a covered transaction, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded. This verification may be accomplished by checking SAM exclusions (https://sam.gov/content/home); collecting a certification from the entity or adding a clause or condition to the covered transactions with that entity. 45 C.F.R. § 75.329 provides the procurement methods required for non-Federal entities. 45 C.F.R. § 75.329(b) states small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Additionally, the Tuscarawas County Health Department has elected to follow the Procurement/Uniform Guidance Policies adopted by the Tuscarawas County Board of Commissioners. The Suspension and debarment section of the policy requires that before a bid process can begin, employees must verify that each vendor bidding on a Federally funded project is not “suspended or debarred.” This means the vendor is in good standing to participate in such projects. Employees must document that the vendor is not suspended or debarred by searching the https://sam.gov/SAM/ website. A print-screen of the search must be included with the bid documentation to verify all vendors are eligible. The Small purchase section of the policy requires, in part, that the Departments will ask for quotes from no less than three sources unless the purchase is for professional services, through a sole supplier or an emergency. Quotes can be written, verbal, or web based. Documentation should always be maintained. If quotes are verbal, documentation must be created and added to the procurement file for reference. The Health Department did not have proper internal controls in place to ensure that procurement procedures were followed as two vendors were paid between $11,107 and $65,187 from the Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases Program and the required three price quotes were not obtained or supporting documentation was not maintained. Also, the Health District did not have the proper internal controls in place to verify that all entities with whom the Health District had entered into covered transactions, had not been suspended or debarred. During testing for the Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases Program, we noted one instance of a payment to a vendor of more than $25,000 and there was no evidence the Health Department checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for the covered transactions in the Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases Program during 2024. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the Health Department should ensure that procurement requirements are followed. In addition, the Health Department should verify that the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Ohio Admin. Code 5101:9-7-03(B)(1) states the County Departments of Job and Family Services shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten-day average for all federal funding. The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 58 days per review of the CR 502 reports in 2024. Therefore, the cash on hand exceeded the allowable number of days by 48 for the year. The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.

31 C.F.R. § 19.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 31 C.F.R. § 19.210 provides that all nonprocurement transactions, as defined in § 19.970 are covered transactions unless listed in § 19.215. 31 C.F.R. § 19.220(b) provides, in part, that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 19.210, and the amount of the contract is expected to equal or exceed $25,000. 31 C.F.R. § 19.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking the EPLS; or (b) collecting a certification from that person if allowed by this rule; or (c) adding a clause or condition to the covered transaction with that person. The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of procurement for the State and Local Fiscal Recovery Fund, Assistance Listing #21.027, we noted one instance where the County had a payment to a vendor of more than $25,000 and there was no evidence the County checked the EPLS, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for one of the three contracts tested with covered transaction in the State and Local Fiscal Recovery Fund during Fiscal Year 2023. Failing to implement appropriate controls may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the EPLS, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Ohio Admin. Code 5101:9-7-03(B)(1) states the County Departments of Job and Family Services shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten-day average for all federal funding. The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 50 days per review of the CR 502 reports in 2023. Therefore, the cash on hand exceeded the allowable number of days by 40 for the year. The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.

45 C.F.R. § 75.405(a) states, in part, that a cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. In order to be allocable, it must benefit both the Federal award and other work of the non-Federal entity and be distributed in proportions that may be approximated using reasonable methods. The Ohio Department of Job and Family Services (ODJFS) has implemented a cost allocation plan approved by the US Department of Health and Human services and has communicated time sampling requirements for said plan to county agencies. This is provided for within 45 C.F.R. § 75.430, which states, in part, that random moment sampling (RMS) may be utilized for allocating salaries and wages to Federal awards. Ohio Admin. Code 5101:9-7-20 outlines the procedures to be utilized for random moment sampling time studies designed to measure activity regarding various Federal programs passed through the Ohio Department of Job and Family Services. Ohio Admin. Code 5101:9-7-20(E)(3) states the employee receiving an observation moment will have forty-eight hours to respond, not including weekends or holidays. In addition, Ohio Admin. Code 5101:9-7-20(E)(2)(b) requires the employee completing the RMS observation moment to complete the comment section. Comments shall demonstrate that the selected program and activity codes support the work being performed by the assigned position at the time of the observation. 1. An employee working on a case shall include a case number or other unique identifier establishing case/client identity. 2. An employee not working on a case enters comments. The employee shall ensure that adequate backup documentation is available to verify the activity being performed. 3. An employee attending a meeting or training at the time of the observation moment shall enter the title/subject, location, and facilitator. 4. An employee on break, at lunch, on leave or on personal business at the time of the observation shall indicate the position was idle. Additionally, Ohio Admin. Code 5101:9-7-20(F) requires the RMS coordinator to review and approved by accepting all observation moment responses within seventy-two hours. The Tuscarawas County Job and Family Service’s (TCJFS) had the following RMS exceptions occur in the 60 hits tested from the quarter selected for 2023: • Two instances (3.3%) where the employee did not timely complete the observation in the forty-eight-hour period. • Two instances (3.3%) where the RMS coordinator did not timely approve the observation in the seventy-two-hour period. • One instance (1.6%) where the employee did not complete the observation properly as the observation stated that the employee was on leave even though she was not. • Three instances (5%) where the employee failed to properly maintain adequate backup documentation to verify the activity being performed. Failure to accurately record the RMS activity and in a timely manner can result in inaccurate allocation of charges to federal programs in the cost pool. The TCJFS should review RMS requirements and establish procedures to ensure that observations are completed and approved timely within the guidelines of Ohio Admin. Code 5101:9-7-20. Additionally, procedures should be implemented to ensure that adequate documentation is maintained to support the activity code charged. This will help to minimize the risk of observations being completed inaccurately and be unaccepted by ODJFS.

2 C.F.R. 180.200 identifies “covered transactions” as nonprocurement or procurement transactions at the primary tier, between a Federal agency and a person; or at the lower tier, between a participant in a covered transaction and another person. 2 C.F.R. § 180.220(b) provides that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 180.210, and the amount of the contract is expected to equal or exceed $25,000. 2 C.F.R. § 376.220 states that in addition to the contracts covered under 2 C.F.R. § 180.220(b), this part also applies to all lower tiers of subcontracts under covered nonprocurement transactions, as permitted under the OMB guidance at 2 C.F.R. § 180.220(c). 2 C.F.R. § 180.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking SAM exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. The County did not have the proper internal controls in place to verify that all entities, with whom the County had entered into covered transactions, had not been suspended or debarred. During testing of procurement for the State and Local Fiscal Recovery Fund, Assistance Listing # 21.027, we noted one instance in which there had been a payment to a vendor of more than $25,000 and there was no evidence the County checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for the only covered transaction in the State and Local Fiscal Recovery Fund during Fiscal Year 2022. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the County should verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

As a part of the Board’s internal control process to ensure compliance with Federal requirements for activities allowed or unallowed, allowable costs/cost principles, and period of performance, the following process has been established. Invoices are received by the Fiscal Manager and reviewed to ensure that the expenses meet grant requirements, including activities allowed or unallowed, allowable costs / cost principles, and period of performance. A list of bills detailing the invoices and the fund/line item that should be charged is then provided to the Board of Directors for approval at the monthly meetings. Once approved, a voucher jacket and a copy of the invoice are provided to the County Auditor’s Office for payment. The County Auditor’s Office provides a copy of the check written that is maintained with each voucher packet. Voucher jackets are signed by the appropriate personnel to indicate their review / approval of the payment. During testing of the Board’s internal control process, the following was noted: • On July 2, 2022, the Board of Directors approved a payment of $12,075 to a vendor using Opioid STR Program (SOR) federal funds captured within the Special Revenue Miscellaneous Federal fund. However, the voucher jacket submitted to the County for payment improperly reflected the payment to be made with General Fund monies. Although the Fiscal Manager identified the mistake and the Board of Directors approved to make the necessary correction on October 19, 2022, the correction was not provided to the County Auditor’s office to follow through with an update to the general ledger. • On May 18, 2022, the Board of Directors approved total payments of $5,529 to two vendors using Substantive Abuse Block Grant Mitigation grant monies of $2,765 and Mental Health Block Grant Mitigation monies of $2,764. Both of these grants are captured within the Special Revenue Community Plan fund. However, the voucher jacket submitted to the County for payment improperly reflected the payment to be made with SOR federal monies. Although the Fiscal Manager identified the mistake and the Board of Directors approved to make the necessary correction on October 19, 2022, the correction was not provided to the County Auditor's Office in order to correct the general ledger. As a result, the General Fund balance was understated by $12,075, the Special Revenue Community Plan Fund balance was overstated by $5,529 and the Special Revenue Miscellaneous Federal fund balance was overstated by $6,546. These fund balance adjustments were agreed upon by management, and the financial statements have been adjusted accordingly. The Board should implement procedures to ensure that disbursements are paid by the appropriate funds and posted to the general ledger correctly.

45 C.F.R. § 75.305(b) states for non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Ohio Admin. Code 5101:9-7-03(B)(1) states the County Departments of Job and Family Services shall have cash management procedures in place to ensure the time elapsing between the receipt of funds and the disbursement of funds does not exceed a ten-day average for all federal funding. The days equivalent cash-on-hand for Tuscarawas County Job and Family Services averaged to 80 days per review of the CR 502 reports in 2022. Therefore, the cash on hand exceeded the allowable number of days by 70 for the year. The Tuscarawas County Job and Family Services should implement internal control procedures that would limit cash draws to amounts only immediately needed. Procedures should include, but are not limited to, a review of expenditures and requesting limited drawdowns that would ensure that cash on hand is expended within the ten-day requirement.

2 C.F.R. § 376.10 gives regulatory effect to the Department of Health and Human Services for 2 C.F.R. Part 180. 2 C.F.R. § 180.220(b) provides that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under § 180.210, and the amount of the contract is expected to equal or exceed $25,000. 2 C.F.R. § 376.220 states that in addition to the contracts covered under 2 C.F.R. § 180.220(b), this part also applies to all lower tiers of subcontracts under covered nonprocurement transactions, as permitted under the OMB guidance at 2 C.F.R. § 180.220(c). 2 C.F.R. § 180.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking SAM exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. 45 C.F.R. § 75.329 provides the procurement methods required for non-Federal entities. 45 C.F.R. § 75.329(b) states small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Additionally, Board Policy VII-A.10 “Federal Funds - Procurement” provides procedures for the small purchases procurement method, including obtaining the required price quotes from at least three qualified sources. The policy also states that the Fiscal Manager shall confirm that the supplier is not debarred or suspended by doing one of the following: checking the Federal government's System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov; collecting a certification from the supplier; or adding a clause or condition to the covered transaction with that supplier. The Board did not have proper internal controls in place to ensure that procurement procedures were followed as three vendors were paid between $10,500 and $114,815 from the Opioid Sate Targeted Response Program, and no price quotes were obtained. Also, the Board did not have the proper internal controls in place to verify that all entities, with whom the Board had entered into covered transactions, had not been suspended or debarred. During testing for Opioid State Targeted Response Grant, we noted three instances of a payment to a vendor of more than $25,000 and there was no evidence the Board checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for the three covered transactions in the Opioid State Targeted Response Grant. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the Board should ensure that procurement requirements are followed. In addition, the Board should verify that the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

45 C.F.R § 75.305(b)(3) states, in part, that the when the reimbursement method is used, the HHS(Health and Human Services) awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the HHS awarding agency or pass-through entity reasonably believes the request to be improper. Additionally, ADAMHS Board of Tuscarawas and Carroll Counties Policies and Procedures Manual, Standard: VII-A.10, Federal Funds - Internal Controls states that the Board shall disburse or obligate federal funds received by the Board in a timely manner to minimize the time elapsing between the transfer or funds to the Board and their disbursement. During testing of the Opioid STR Program, we noted that there were no controls in place to ensure that payments were made within 30 days. This is evident as all 7 cash drawdowns were primarily based on invoices received that were not paid by the time of the drawdown. As such, we noted that $334,110 out of $386,243 in 2022 federal expenditures had invoices that were not paid within 30 days of receipt as required. Also, we determined that the Board's policy is not in compliance with 45 C.F.R. § 75.305. The Board should implement procedures to ensure that invoices are paid within 30 days of receipt in order to comply with 45 C.F.R § 75.305.

45 C.F.R. §75.320(d) provides required procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. The Board purchased three equipment items, each costing $38,271 for a total of $114,815 that were each shipped to the fire departments for the City of New Philadelphia, the City of Dover and the City of Uhrichsville, for the purpose of decontaminating equipment exposed to narcotics. However, the Board neglected to include these items on their property records and did not place inventory tags on the units to indicate the fire departments that these were the property of the Board. The Board should implement internal controls to ensure compliance with the equipment management requirements identified above, when equipment is acquired with federal funds. Such procedures should include, but are not limited to, ensuring that equipment purchased with federal funds is properly included on the Board’s property records and that an inventory tag is affixed to the equipment. This will aide in safeguarding the items, as the equipment is located off-site.

45 C.F.R. § 75.352(a) and (d) requires that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Required information includes federal award identification, federal award notification and all requirements imposed by the pass through-entity on the subrecipient so that the Federal award is used in accordance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Although the Board entered into an agreement with Ohio Guidestone for several types of services, the Board did not include the required information indicating that the provider was a subrecipient of the Opioid State Targeted Response grant. The Board also did not properly monitor the activity of the subrecipient related to the grant requirements. Without adequate procedures in place to monitor subrecipient compliance with federal statutes, laws and regulations, there is an increased risk subrecipients may misuse subaward funds for unauthorized purposes. This could lead to fines, penalties, or repayment of program funding being imposed by the federal grantor agency. The Board should evaluate its current control procedures and processes over subrecipient monitoring and update them as necessary to reasonably ensure compliance with 45 C.F.R. § 75.352. The Board should ensure that subrecipients are properly notified of the subaward along with the requirements imposed by the pass through-entity on the subrecipient. The Board should also perform monitoring procedures over the subrecipient activity to ensure that the grant requirements are being met.

2 C.F.R. ? 376.10 gives regulatory effect to the Department of Health and Human Services for 2 C.F.R. Part 180. 2 C.F.R. ? 180.220(b) provides that a contract for goods or services is a covered transaction if the contract is awarded by a participant in a nonprocurement transaction that is covered under ? 180.210, and the amount of the contract is expected to equal or exceed $25,000. 2 C.F.R. ? 376.220 states that in addition to the contracts covered under 2 C.F.R. ? 180.220(b), this part also applies to all lower tiers of subcontracts under covered nonprocurement transactions, as permitted under the OMB guidance at 2 C.F.R. ? 180.220(c). 2 C.F.R. ? 180.300 provides that when you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) checking SAM exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. 45 C.F.R. ? 75.329 provides the procurement methods required for non-Federal entities. 45 C.F.R. ? 75.329(b) states small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Additionally, Board Policy VII-A.10 ?Federal Funds - Procurement? provides procedures for the small purchases procurement method, including obtaining the required price quotes from at least three qualified sources. The policy also states that the Fiscal Manager shall confirm that the supplier is not debarred or suspended by doing one of the following: checking the Federal government's System for Award Management, which maintains a list of such debarred or suspended vendors at www.sam.gov; collecting a certification from the supplier; or adding a clause or condition to the covered transaction with that supplier. The Board did not have proper internal controls in place to ensure that procurement procedures were followed as one vendor was paid $13,505 from the Opiod Sate Targeted Response Program and no price quotes were obtained. Also, the Board did not have the proper internal controls in place to verify that all entities, with whom the Board had entered into covered transactions, had not been suspended or debarred. During testing for Opioid State Targeted Response Grant, we noted one instance in which each program had a payment to a vendor of more than $25,000 and there was no evidence the Board checked the SAM exclusions, collected a certification from the entity, or added a clause or condition to the covered transaction with the vendor. Due to the deficient internal control structure, the required verification was not completed for the two covered transactions in the Opioid State Targeted Response Grant. Failing to have the appropriate controls in place may result in vendors receiving federal funds that are suspended or debarred. Prior to contracting with vendors that will be paid with federal funds, the Board should ensure that procurement requirements are followed. In addition, the Board should verify that the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.

45 C.F.R ? 75.305(b)(3) states, in part, that the when the reimbursement method is used, the HHS (Health and Human Services) awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the HHS awarding agency or pass-through entity reasonably believes the request to be improper. Additionally, ADAMHS Board of Tuscarawas and Carroll Counties Policies and Procedures Manual, Standard: VII-A.10, Federal Funds - Internal Controls states that the Board shall disburse or obligate federal funds received by the Board in a timely manner to minimize the time elapsing between the transfer or funds to the Board and their disbursement. During testing of the Opiod STR Program, we noted that there were no controls in place to ensure that payments were made within 30 days. This is evident as all 7 cash drawdowns were primarily based on invoices received that were not paid by the time of the drawdown. As such, we noted that $216,673 out of $221,892 in 2021 federal expenditures had invoices that were not paid within 30 days of receipt as required. Also, we determined that the Board's policy is not in compliance with 45 C.F.R. ? 75.305. The Board should implement procedures to ensure that invoices are paid within 30 days of receipt in order to comply with 45 C.F.R ? 75.305.

45 C.F.R. ? 75.352(a) and (d) requires that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. Required information includes federal award identification, federal award notification and all requirements imposed by the pass through-entity on the subrecipient so that the Federal award is used in accordance with Federal statues, regulations, and the terms and conditions of the Federal award. Additionally, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Although the Board entered into an agreement with Ohio Guidestone for several types of services, the Board did not include the required information indicating that the provider was a subrecipient of the Opioid State Targeted Response grant. The Board also did not properly monitor the activity of the subrecipient related to the grant requirements. Without adequate procedures in place to monitor subrecipient compliance with federal statutes, laws and regulations, there is an increased risk subrecipients may misuse subaward funds for unauthorized purposes. This could lead to fines, penalties, or repayment of program funding being imposed by the federal grantor agency. The Board should evaluate its current control procedures and processes over subrecipient monitoring and update them as necessary to reasonably ensure compliance with 45 C.F.R. ? 75.352. The Board should ensure that subrecipients are properly notified of the subaward along with the requirements imposed by the pass through-entity on the subrecipient. The Board should also perform monitoring procedures over the subrecipient activity to ensure that the grant requirements are being met.

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