Porter County

Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Federal Agency: Department of Treasury Federal Assistance Listing Number: Number 21.027 Criteria: Procurement, suspension and debarment – CFR Part 180.300 states, “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.” Condition: An effective internal control system was not in place at the County to ensure compliance with federal requirements related to suspension and debarment compliance requirements. Questioned Costs: None noted. Context: The County entered into contracts with vendors that were reimbursed through funds granted under the Coronavirus State and Local Fiscal Recover Funds program. The County failed to retain documentation of the verification of suspension or disbarment to document that a covered transaction was not entered into with a suspended or debarred entity. Effect or Potential Effect: Goods or services were procured without retaining documentation that appropriate compliance guidelines were followed. Cause: The County’s internal controls did not require retention of suspension and debarment checks being performed. Recommendation: Management should perform a review to ensure controls are put into place and followed and documented for all applicable vendors and that documentation is retained to show the necessary suspension and debarment checks are completed. Views of Responsible Officials and Planned Corrective Actions: For the views of responsible officials, refer to the Corrective Action Plan.

Federal Program Name: Highway Planning and Construction Program Federal Agency: U.S. Department of Transportation Pass-through Entity: Indiana Department of Transportation Federal Assistance Listing Title and Number: Highway Planning and Construction Program, 20.205 Award Year: 2014, 2015, 2018 Criteria or Specific Requirement: Under Uniform Guidance compliance requirements for Procurement (2 CFR 200.318(i)), contract files must be sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. In cases where competition was limited, such as scenarios where specific qualifications and competence are required, the files should provide evidence that the limitation on competition was justified. Condition: The County entered into various professional services contracts for engineering and consulting services for its highway grant programs but did not maintain appropriate documentation to support its procurement decisions. Questioned Costs: $0 Context: During our testing of procurement requirements, 3 out of 3 projects selected for testing included contracts for engineering/consulting services. For 2 of the 3 contracts, the County selected based on qualifications/competence established by the state Department of Transportation rather than a formal RFP process but did not have appropriate documentation as evidence of their basis for conclusion. The other contract tested was subject to an RFP process but did not have appropriate documentation to support how the chosen firm was selected. Our sample was not, and was not intended to be, statistically valid. Effect: Contracts were approved without appropriate documentation to comply with Uniform Guidance requirements. Cause: Adequate supporting documentation on the procurements was not obtained or maintained within project or vendor files due to oversight in administration of the program. Repeat Finding: No Recommendation: We recommend the County revisit controls over this compliance requirement to ensure that appropriate documentation is gathered and retained within its procurement files to support all Federally funded purchasing decisions. Views of Responsible Officials and Planned Corrective Action: See corrective action plan prepared by management attached.

Federal Program Name: Highway Planning and Construction Program Federal Agency: U.S. Department of Transportation Pass-through Entity: Indiana Department of Transportation Federal Assistance Listing Title and Number: Highway Planning and Construction Program, 20.205 Award Year: 2014, 2015, 2018 Criteria or Specific Requirement: In order to ensure compliance with Equipment and Real Property Management requirements under the Uniform Guidance, management must establish controls so that records properly track federal property and equipment separate from non-federal property and equipment. Condition: The County has various real property (roads and bridges) that were funded by Federal awards. While its asset records are designed to capture and identify Federal participation, that field within its road and bridge asset listing has not been populated. Questioned Costs: $0 Context: During our testing of the three highway grant funded projects for 2021, we attempted to trace the capitalizable portion of Federal expenses back to capital asset records. We noted that for all three projects, the asset listing did not identify the related road/bridge assets as being Federally funded. Our sample was not, and was not intended to be, statistically valid. Effect: The County asset listing for road and bridge assets is not being maintained in a manner that complies with Federal real property management requirements. Because it has not identified in the asset records which road and bridge assets include Federal participation, the County would need to revisit and update the listing to ensure compliance moving forward. Cause: Sufficient detail in the capital asset listing was not maintained due to an oversight in administration of the program. Repeat Finding: No Recommendation: We recommend the County revisit its road and bridge asset records to ensure that Federally funded real property is identified. Views of Responsible Officials and Planned Corrective Action: See corrective action plan prepared by management attached.

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