EIN: 356000194
UEI: HLX8KKCL6UA4
Data as of August 20, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 7, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 7, 2025, which was (559 days ago).
What is a management decision? →Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Noncompliance Criteria or Specific Requirement – Allowable Costs/Activities: Pursuant to the restrictions set forth Division LL, Section 103 of the Consolidated Appropriations Act, 2023, Treasury’s Interim Final Rule and Final Rule at 31 CFR Part 35, and frequently asked questions addressed by the Treasury, recipients must demonstrate that costs incurred are allowable under the relevant statutory provisions and consistent with the purpose of the State and Local Fiscal Recovery Funds. Recipients are allowed to use funds to respond to the public health and negative economic impacts of the pandemic, replace lost public sector revenue, provide premium pay for essential workers and invest in water, sewer and broadband infrastructure. Activities unallowed include those that are an offset as a reduction in net tax revenue, deposits into pension funds, debt service or replenishing financial reserves, satisfaction of settlements and judgments and programs, services or capital expenditures that undermine efforts to stop the spread of COVID-19. Condition: Expenditures were identified in relation to activities allowed or unallowed and allowable costs compliance requirements that were not allowable under the grant. Questioned Costs: Questioned costs totaling $190,000. Context: Out of a population of 73 expenditures, 8 were selected for testing. There was one error identified in testing in which $60,000 was paid for an unallowable settlement payment. Our sample was not intended to be statistically valid. Effect: Nonallowable costs were charged to the grant. Cause: Failure to maintain sufficient review of the allowable costs or activities being charged to the grant. Identification as a Repeat Finding: No Recommendation: We recommend that the County consider reviewing the guidance regarding the allowable costs and activities. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including a thorough review of the compliance requirements. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Contact Person Responsible for Corrective Action: Abby Doyle, Chief Deputy Auditor Contact Phone Number: (574) 235-9668 ext.7201 Views of Responsible Official: County Auditor’s office will work with the County Attorney and financial consultant to make sure that only allowable costs are paid with American Rescue Plan (ARP) funds. The expenditures of $190,000 in settlements that were determined to be nonallowable in 2023 were paid back by the County’s Worker’s Compensation/Casualty Fund on June 14, 2024.” Description of Corrective Action Plan: Effective June 24, 2023, the County Auditor’s office will utilize the County Attorney and financial consultant to verify allowable costs are being incurred with American Rescue Plan (ARP) funds.
Federal Agencies: U.S. Department of Treasury and Department of Transportation Federal Program Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds and Highway Planning and Construction Cluster Assistance Listing Numbers: 21.027 and 20.205 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agencies: Indiana Finance Authority and Indiana Department of Transportation Pass-Through Numbers: 21.027: Unknown, 20.205: Des. 1593056, Des. 1400296, Des. 1900448, Des. 1702832, Des. 1400638, Des. 1400639, Des. 2100024, and Des. 2101602 Type of Finding: • Significant Deficiency Criteria or Specific Requirement – Procurement, Suspension, and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR § 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the “List of Parties Excluded from Federal Procurement and Nonprocurement Programs” during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls, that would likely be effective in preventing, detecting and correcting, noncompliance. Questioned Costs: None Context: It was noted that for ALN 21.027, three files selected for testing from a population of twenty-six files, and for ALN 20.205, one file selected for testing from a population of six, did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes, 2022-002 Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Contact Person Responsible for Corrective Action: Abby Doyle, Chief Deputy Auditor Contact Phone Number: (574) 235-9668 ext. 7201 Views of Responsible Official: We concur with the audit finding with respect to the failure of having processes and procedures in place to prohibit from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Description of Corrective Action Plan: Currently, the County requires all new vendors to complete the attached “Vendor Registration Form”. On page 5 the vendor acknowledges they have not or are currently not suspended and debarred. A new step that Procurement implemented as of July 14, 2023 was verification of vendor’s status on sam.gov and attaching the screenshot to the LOW system. Procurement will update their vendor policy to specifically include this step in 2024. On July 14, 2023, County Attorney issued a statement enforcing the following verbiage to be added to all contracts. Debarment and Suspension 1. Contractor certifies, by entering into this Agreement, that neither it nor its principals are presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from or ineligible for participation in any Federal assistance program by and Federal department or agency, or by any department, agency, or political subdivision of the State of Indiana. The term “principal” for purposes of the Agreement means an officer, director, owner, partner, key employee, or the person with primary management or supervisory responsibilities, or a person who has a critical influence on or substantive control over the operation of the Contractor. 2. Contractor certifies, by entering into this Agreement, that is does not engage in investment activities in Iran as more particularly described in IC 5-22-16.5. 3. Contractor shall provide immediate written notice to County if, at any time after entering into this Agreement, Contractor learns that its certifications were erroneous when submitted, or Contractor is debarred, suspended, proposed for debarment, declared ineligible, has been included on a list or received notice of intent to include on a list created pursuant to IC 5-22-16.5, voluntarily excluded from or becomes ineligible for participation in any Federal assistance program. Any such event shall be cause for termination of this agreement as provided herein. 4. Contractor shall not subcontract with any party which is debarred or suspended or is otherwise excluded from on ineligible for participation in any Federal assistance programs by any federal department or agency, or by any department, agency or political subdivision of the State of Indiana. Next, the County Attorney provided guidance to all departments to verify vendors prior to engaging in a contract. Below is the verbiage from the County Attorney to staff on July 14, 2023. The state has asked us to verify that the entity we are contracting with is not debarred by visiting the following websites and running a search: https://sam.gov/content/exclusions https://www.in.gov/idoa/procurement/supplier-resource-center/supplier-responsibilities/ Termination for Failure of Funding Notwithstanding any other provision of this Agreement, if funds for the continued fulfillment of this Agreement by County are at any time insufficient or not forthcoming through a failure of any entity to appropriate funds or otherwise, then the County shall have the right to terminate this Agreement without penalty by giving written notice documenting the lack of funding, in which instance this Agreement shall terminate and become null and void on the last day of the fiscal period for which appropriations were received. County agrees to make its best efforts to obtain sufficient funds, including but not limited to, requesting in its budget for each fiscal period during the term hereof sufficient funds to meet its obligations hereunder in full. For public works projects: Compliance With E-Verify Program. Pursuant to IC 22-5-1.7, Consultant shall enroll in and verify the work eligibility status of all newly hired employees of Consultant through the E-Verify Program (“Program”). Consultant is not required to verify the work eligibility status of all newly hired employees through the Program if the Program no longer exists. Consultant and its subcontractors shall not knowingly employ or contract with an unauthorized alien or retain an employee or contract with a person that Consultant or its subcontractor subsequently learns is an unauthorized alien. If Consultant violates this Section, County shall require Consultant to remedy the violation not later than thirty (30) days after County notifies Consultant. If Consultant fails to remedy the violation within the thirty (30) day period, County shall terminate the contract for breach of contract. If County terminates the contract, Consultant shall, in addition to any other contractual remedies, be liable to County for actual damages. There is a rebuttable presumption that Consultant did not knowingly employ an unauthorized alien if Consultant verified the work eligibility status of the employee through the Program. If Consultant employs or contracts with an unauthorized alien but County determines that terminating the contract would be detrimental to the public interest or public property, County may allow the contract to remain in effect until County procures a new contractor. Consultant shall, prior to performing any work, require each subcontractor to certify to Consultant that the subcontractor does not knowingly employ or contract with an unauthorized alien and has enrolled in the Program. Consultant shall maintain on file a certification from each subcontractor throughout the duration of the Project. If Consultant determines that a subcontractor is in violation of this Section, Consultant may terminate its contract with the subcontractor for such violation. Pursuant to IC 22-5-1.7 a fully executed affidavit affirming that the business entity does not knowingly employ an unauthorized alien and confirming Consultant’s enrollment in the Program, unless the Program no longer exists, shall be filed with County prior to the execution of this Agreement. This Agreement shall not be deemed fully executed until such affidavit is filed with the County. Lastly, the Commissioner’s Assistant will check incoming contracts from departments to ensure proper documentation is attached that verifies the vendor has been checked through sam.gov and in.gov. Once the contract has been approved by the Commissioners, the Auditor’s office will then upload the contract and supporting documents onto Gateway. Completion Date: June 24, 2024
2022-002
Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Program Year: January 1, 2023 – December 31, 2023 Pass-Through Agency: Indiana Finance Authority Pass-Through Number: Unknown Type of Finding: • Significant deficiency and noncompliance Criteria or Specific Requirement – Subrecipient Monitoring: Pursuant to 2 CFR § 200.331, non-Federal entities can award subawards for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the subrecipient. In addition, pursuant to 2 CFR § 200.332, the non-Federal entity must identify to the subrecipient as a subaward and includes the Federal award identification. The non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, incompliance with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The County could not provide support that it had sufficient review of the subrecipient during the year on a consistent basis. The County had not properly designed or implemented a system of internal controls that would likely be effective in preventing, detecting, and correcting, noncompliance. Questioned Costs: None Context: It was noted that the file selected for testing did not have documented evidence supporting that the County had sufficient monitoring and communication of the subrecipient. From a population of three files, one was selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support that the subrecipients were being monitored. Cause: Failure to maintain sufficient monitoring of the subrecipient Identification as a Repeat Finding: Yes, 2022-003 Recommendation: We recommend the County maintain adequate communication and documentation with the subrecipients to ensure compliance with the subrecipients requirement. This documentation could include a quarterly communication, receipt of the audited financial statements and single audit report, if applicable. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Contact Person Responsible for Corrective Action: Abby Doyle, Chief Deputy Auditor Contact Phone Number: (574) 235-9668 ext.7201 Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored the subrecipient agrees for the 50% matching requirement, and the subrecipient was paid properly. However, we did not obtain quarterly progress reports on the program. Description of Corrective Action Plan: On March 4, 2024, the County contacted each entity that signed a sub-recipient agreement for American Rescue Plan (ARP) funding and asked them to complete and sign the attached Proof of Project Efforts Schedule. The schedule provides the County with a description of the project and uses of ARP funds. In addition, the schedule provides a listing of project expenditures and paid invoices. The completed forms have been received and filed. Completion Date: March 29, 2024
2022-003
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 16, 2024. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by July 16, 2024, which was (765 days ago).
What is a management decision? →Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027 Federal Award Program Year: January 1, 2022 - December 31, 2022 Pass-through Agency: Indiana Finance Authority Pass-through Number: Unknown Type of Finding: Significant Deficiency Criteria or Specific Requirement - Procurement, Suspension and Debarment: Pursuant to 31 CFR § 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with the 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 of the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the "List of Parties Excluded from Federal Procurement and Nonprocurement Programs" during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls which would include appropriate segregation of duties that would likely be effective in preventing, detecting and correcting noncompliance. Questioned Costs: None Context: It was noted that the two files selected for testing did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. From a population of thirteen files, two were selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: Yes Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Views of Responsible Official: We concur with the audit finding with respect to the failure of having processes and procedures in place to prohibit from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Description of Corrective Action Plan: Currently, the County requires all new vendors to complete the attached “Vendor Registration Form”. On page 5 the vendor acknowledges they have not or are currently not suspended and debarred. A new step that Procurement implemented as of July 14, 2023 was verification of vendor’s status on sam.gov and attaching the screenshot to the LOW system. Procurement will update their vendor policy to specifically include this step. On July 14, 2023, County Attorney issued a statement enforcing the following verbiage to be added to all contracts. Debarment and Suspension: 1. Contractor certi¿es, by entering into this Agreement, that neither it nor its principals are presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from or ineligible for participation in any Federal assistance program by and Federal department or agency, or by any department, agency, or political subdivision of the State of Indiana. The term “principal” for purposes of the Agreement means an o¿cer, director, owner, partner, key employee, or the person with primary management or supervisory responsibilities, or a person who has a critical in¿uence on or substantive control over the operation of the Contractor. 2. Contractor certi¿es, by entering into this Agreement, that is does not engage in investment activities in Iran as more particularly described in IC 5-22-16.5. 3. Contractor shall provide immediate written notice to County if, at any time after entering into this Agreement, Contractor learns that its certi¿cations were erroneous when submitted, or Contractor is debarred, suspended, proposed for debarment, declared ineligible, has been included on a list or received notice of intent to include on a list created pursuant to IC 5-22-16.5, voluntarily excluded from or becomes ineligible for participation in any Federal assistance program. Any such event shall be cause for termination of this agreement as provided herein. 4. Contractor shall not subcontract with any party which is debarred or suspended or is otherwise excluded from on ineligible for participation in any Federal assistance programs by any federal department or agency, or by any department, agency or political subdivision of the State of Indiana. Next, the County Attorney provided guidance to all departments to verify vendors prior to engaging in a contract. Below is the verbiage from the County Attorney to staff on July 14, 2023. The state has asked us to verify that the entity we are contracting with is not debarred by visiting the following websites and running a search: https://sam.gov/content/exclusions https://www.in.gov/idoa/procurement/supplier-resource-center/supplier-responsibilities/ Termination for Failure of Funding: Notwithstanding any other provision of this Agreement, if funds for the continued fulfillment of this Agreement by County are at any time insufficient or not forthcoming through a failure of any entity to appropriate funds or otherwise, then the County shall have the right to terminate this Agreement without penalty by giving written notice documenting the lack of funding, in which instance this Agreement shall terminate and become null and void on the last day of the fiscal period for which appropriations were received. County agrees to make its best efforts to obtain sufficient funds, including but not limited to, requesting in its budget for each fiscal period during the term hereof sufficient funds to meet its obligations hereunder in full. For public works projects: Compliance with E-verify Program. Pursuant to IC 22-5-1.7, Consultant shall enroll in and verify the work eligibility status of all newly hired employees of Consultant through the E-Verify Program (“Program”). Consultant is not required to verify the work eligibility status of all newly hired employees through the Program if the Program no longer exists. Consultant and its subcontractors shall not knowingly employ or contract with an unauthorized alien or retain an employee or contract with a person that Consultant or its subcontractor subsequently learns is an unauthorized alien. If Consultant violates this Section, County shall require Consultant to remedy the violation not later than thirty (30) days after County notifies Consultant. If Consultant fails to remedy the violation within the thirty (30) day period, County shall terminate the contract for breach of contract. If County terminates the contract, Consultant shall, in addition to any other contractual remedies, be liable to County for actual damages. There is a rebuttable presumption that Consultant did not knowingly employ an unauthorized alien if Consultant verified the work eligibility status of the employee through the Program. If Consultant employs or contracts with an unauthorized alien but County determines that terminating the contract would be detrimental to the public interest or public property, County may allow the contract to remain in effect until County procures a new contractor. Consultant shall, prior to performing any work, require each subcontractor to certify to Consultant that the subcontractor does not knowingly employ or contract with an unauthorized alien and has enrolled in the Program. Consultant shall maintain on file a certification from each subcontractor throughout the duration of the Project. If Consultant determines that a subcontractor is in violation of this Section, Consultant may terminate its contract with the subcontractor for such violation. Pursuant to IC 22-5-1.7 a fully executed affidavit affirming that the business entity does not knowingly employ an unauthorized alien and confirming Consultant’s enrollment in the Program, unless the Program no longer exists, shall be filed with County prior to the execution of this Agreement. This Agreement shall not be deemed fully executed until such affidavit is filed with the County. Lastly, the Commissioner’s Assistant will check incoming contracts from departments to ensure proper documentation is attached that verifies the vendor has been checked through sam.gov and in.gov. Once the contract has been approved by the Commissioners, the Auditor’s office will then upload the contract and supporting documents onto Gateway. Completion Date: December 20, 2023
2021-002
Federal Agency: U.S. Department of the Treasury Federal Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number 21.027 Fedearl Award Program Year: January 1, 2022 - December 31, 2022 Pass-through Agency: Indiana Finance Authority Pass-through Number: Unknown Type of finding: significant deficiency in internal control over compliance, other matter. Criteria or Specific Requirement - Subrecipient Monitoring: Pursuant to 2 CFR § 200.331, non-Federal entities can award subawards for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient. In addition, pursuant to 2 CFR 200.332, the non-Federal entity must identify to the subrecipient as a subaward and includes the Federal award identification. The non-Federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Fedderal statutes, regulations, and the terms and conditions of the subaward. Condition: The County could not provide support that it had sufficient review of the subrecipient during the year on a consistent basis. The County had not properly designed or implemented a system of internal controls that would likely be effective in preventing, detecting, and correcting, noncompliance. Question Costs: None Context: It was noted that the file selected for testing did not have documented evidence supporting that the County had sufficient monitoring and communication of the subrecipient. The file selected had a qualified opinion relating to their single audit that the County was wnaware. From a population of ten files, one was selected for testing. Our sample was not intended to be statistically valid. Effec: The County was unable to support that the subrecipients were being monitored. Cause: Failue to maintain sufficient monitoring of the subrecipient. Identification as a repeat finding: No Recommendation: We recommend that the County maintain adequate communication and documentation with the subrecipients to ensure compliance with the subrecipients requirement. This documentation could include a quarterly communication and receipt of the audited financial statements and single audit report, if applicable. Views of responsible officials and planned corrective action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support subrecipient monitoring processes are in place. Person responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored the subrecipient agreement for the 50% matching requirement, and the subrecipient was paid properly. However, we did not obtain quarterly progress reports on the program. Description of Corrective Action Plan: Effective January 1st, 2024, the County will obtain progress reports on a quarterly basis for all active subrecipient agreements. Completion date: December 20, 2023.
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on August 13, 2023. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by February 13, 2024, which was (919 days ago).
What is a management decision? →Federal Program: COVID-19 Emergency Rental Assistance Program, Assistance Listing Number 21.023 Program Year: January 1, 2021 - December 31, 2021 Criteria or Specific Requirement - Reporting: Pursuant to 45 CFR ? 75.342, the County must submit performance reports at the interval required by the HHS awarding agency or pass-through entity. In addition, pursuant to 2 CFR 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards 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 of the "Internal Control Intregrated Framework" issued by the Comptroller General of the United States of the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County was unable to provide certain reporting that was required to be submitted under the terms and conditions of the Emergency Rental Assistance (ERA) Program. The County had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, detecting and correcting noncompliance. Questioned Costs: None Context: The County was unable to provide copies of the monthly reporting that was completed under the terms and conditions of the ERA Program. While the County was able to demonstrate the reporting had been filed, we were unable to test the information as indicated within the compliance supplement. Effect: The County was unable to provide the reports submitted. Cause: Failure to maintain sufficient records. Identification as a Repeat Finding: No Recommendation: We recommend that the County ensure copies of all of the reporting items are retained. Policies and procedures related to retention should be modified to ensure reports are retained. Views of Responsible Officials and Planned Corrective Action: Due to turnover occurring within the County after the reports were filed, management was unable to provide the underlying information as well as the reports that were filed. A new individual has been tasked with ensuring copies of reports are retained in the future. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Views of Responsible Official: We concur with the audit finding with respect to the failure to maintain sufficient records under the terms and conditions of the Emergency Rental Assistance (ERA) Programs. Description of Corrective Action Plan: Although monthly and quarterly reporting of the Emergency Rental Assistance (ERA) Programs was submitted timely to the U.S. Treasury, hard copies of the monthly reports were not kept onsite. The Auditor has kept copies since the change in staff and will continue to retain documentation following the retention schedule set forth by the State. Completion Date: July 17, 2023
Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number 21.027 Program Year: January 1, 2021 - December 31, 2021 Criteria or Specific Requirement - Procurement, Suspension and Debarment: Pursuant to 31 CFR ? 19.300, non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. The non-Federal entity must verify that the contracted entity is not suspended or debarred or otherwise excluded. In addition, pursuant to 2 CFR 200.303, which states in part, the non-Federal entity must establish and maintain an effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with the 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 of the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission. Condition: The County could not provide support that it had reviewed the "List of Parties Excluded from Federal Procurement and Nonprocurement Programs" during their procurement procedures on a consistent basis. The County had not properly designed or implemented a system of internal controls which would include appropriate segregation of duties that would likely be effective in preventing, detecting and correcting noncompliance. Questioned Costs: None Context: It was noted that the files selected for testing did not have documented evidence supporting that the County had determined that the contracted parties were not suspended or debarred. From a population of ten files, one was selected for testing. Our sample was not intended to be statistically valid. Effect: The County was unable to support vendors were not suspended or debarred. Cause: Failure to maintain sufficient procurement records. Identification as a Repeat Finding: No Recommendation: We recommend that the County maintain adequate documentation to ensure compliance with the suspension and debarment requirement. This documentation could include a print out from the Excluded Parties List System maintained by the General Services Administration, collection of a certification from the contracted party, or adding a clause or condition to the covered transaction with the contracted party. Views of Responsible Officials and Planned Corrective Action: The County is aware of the compliance requirement and has implemented additional procedures, including certain of those identified in the recommendation above, to be able to support suspension and debarment processes are in place. Persons responsible for implementing: Abby Doyle, Chief Deputy Auditor Anticipated completion date: Completed.
Views of Responsible Official: We concur with the audit finding with respect to the failure of having processes and procedures in place to prohibit from contracting with or making subawards under covered transactions to parties that are suspended and debarred or whose principals are suspended or debarred. Description of Corrective Action Plan: Currently, the County requires all new vendors to complete the attached ?Vendor Registration Form?. On page 5 the vendor acknowledges they have not or are currently not suspended and debarred. A new step that Procurement implemented as of July 14, 2023 was verification of vendor?s status on sam.gov and attaching the screenshot to the LOW system. Procurement will update their vendor policy to specifically include this step. On July 14, 2023, County Attorney issued a statement enforcing the following verbiage to be added to all contracts. Debarment and Suspension: 1. Contractor certi?es, by entering into this Agreement, that neither it nor its principals are presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from or ineligible for participation in any Federal assistance program by and Federal department or agency, or by any department, agency, or political subdivision of the State of Indiana. The term ?principal? for purposes of the Agreement means an o?cer, director, owner, partner, key employee, or the person with primary management or supervisory responsibilities, or a person who has a critical in?uence on or substantive control over the operation of the Contractor. 2. Contractor certi?es, by entering into this Agreement, that is does not engage in investment activities in Iran as more particularly described in IC 5-22-16.5. 3. Contractor shall provide immediate written notice to County if, at any time after entering into this Agreement, Contractor learns that its certi?cations were erroneous when submitted, or Contractor is debarred, suspended, proposed for debarment, declared ineligible, has been included on a list or received notice of intent to include on a list created pursuant to IC 5-22-16.5, voluntarily excluded from or becomes ineligible for participation in any Federal assistance program. Any such event shall be cause for termination of this agreement as provided herein. 4. Contractor shall not subcontract with any party which is debarred or suspended or is otherwise excluded from on ineligible for participation in any Federal assistance programs by any federal department or agency, or by any department, agency or political subdivision of the State of Indiana. Next, the County Attorney provided guidance to all departments to verify vendors prior to engaging in a contract. Below is the verbiage from the County Attorney to staff on July 14, 2023. The state has asked us to verify that the entity we are contracting with is not debarred by visiting the following websites and running a search: https://sam.gov/content/exclusions https://www.in.gov/idoa/procurement/supplier-resource-center/supplier-responsibilities/ Termination for Failure of Funding: Notwithstanding any other provision of this Agreement, if funds for the continued fulfillment of this Agreement by County are at any time insufficient or not forthcoming through a failure of any entity to appropriate funds or otherwise, then the County shall have the right to terminate this Agreement without penalty by giving written notice documenting the lack of funding, in which instance this Agreement shall terminate and become null and void on the last day of the fiscal period for which appropriations were received. County agrees to make its best efforts to obtain sufficient funds, including but not limited to, requesting in its budget for each fiscal period during the term hereof sufficient funds to meet its obligations hereunder in full. For public works projects: Compliance with E-verify Program. Pursuant to IC 22-5-1.7, Consultant shall enroll in and verify the work eligibility status of all newly hired employees of Consultant through the E-Verify Program (?Program?). Consultant is not required to verify the work eligibility status of all newly hired employees through the Program if the Program no longer exists. Consultant and its subcontractors shall not knowingly employ or contract with an unauthorized alien or retain an employee or contract with a person that Consultant or its subcontractor subsequently learns is an unauthorized alien. If Consultant violates this Section, County shall require Consultant to remedy the violation not later than thirty (30) days after County notifies Consultant. If Consultant fails to remedy the violation within the thirty (30) day period, County shall terminate the contract for breach of contract. If County terminates the contract, Consultant shall, in addition to any other contractual remedies, be liable to County for actual damages. There is a rebuttable presumption that Consultant did not knowingly employ an unauthorized alien if Consultant verified the work eligibility status of the employee through the Program. If Consultant employs or contracts with an unauthorized alien but County determines that terminating the contract would be detrimental to the public interest or public property, County may allow the contract to remain in effect until County procures a new contractor. Consultant shall, prior to performing any work, require each subcontractor to certify to Consultant that the subcontractor does not knowingly employ or contract with an unauthorized alien and has enrolled in the Program. Consultant shall maintain on file a certification from each subcontractor throughout the duration of the Project. If Consultant determines that a subcontractor is in violation of this Section, Consultant may terminate its contract with the subcontractor for such violation. Pursuant to IC 22-5-1.7 a fully executed affidavit affirming that the business entity does not knowingly employ an unauthorized alien and confirming Consultant?s enrollment in the Program, unless the Program no longer exists, shall be filed with County prior to the execution of this Agreement. This Agreement shall not be deemed fully executed until such affidavit is filed with the County. Lastly, the Commissioner?s Assistant will check incoming contracts from departments to ensure proper documentation is attached that verifies the vendor has been checked through sam.gov and in.gov. Once the contract has been approved by the Commissioners, the Auditor?s office will then upload the contract and supporting documents onto Gateway. Completion Date: July 18, 2023
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2020. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 30, 2021, which was (1969 days ago).
What is a management decision? →FINDING 2019-003 Subject: Child Support Enforcement - Allowable Costs/Cost Principles Federal Agency: Department of Health and Human Services Federal Program: Child Support Enforcement CFDA Number: 93.563 Federal Award Number and Year (or Other Identifying Number): 1504INSCEC Pass-Through Entity: Indiana Department of Child Services Compliance Requirement: Allowable Costs/Cost Principles Audit Findings: Material Weakness, Other Matters Condition and Context An effective internal control system was not in place at the County to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Cost Principles compliance requirement related to the cost allocation plan. A County official certified that the cost allocation plan was true and correct by signing the Certificate of Indirect Cost form, but this was not effective and did not ensure compliance. Due to the lack of effective controls, the cost allocation plan did not include the organizational chart and the allocated cost pool for building use. The lack of effective internal controls and the noncompliance were isolated to the items not included in the cost allocation plan. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) 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 or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR Part 200, Appendix V, part A states in part: "1. Most governmental units provide certain services, such as motor pools, computer centers, purchasing, accounting, etc., to operating agencies on a centralized basis. Since federally supported awards are performed within the individual operating agencies, there needs to be a process whereby these central service costs can be identified and assigned to benefitted activities on a reasonable and consistent basis. The central service cost allocation plan provides that process. All costs and other data used to distribute the costs included in the plan should be supported by formal accounting and other records that will support the propriety of the costs assigned to Federal awards. . . ." 2 CFR Part 200, Appendix V, part E states in part: ". . . 1. General All proposed plans must be accompanied by the following: an organization chart sufficiently detailed to show operations including the central service activities of the state/local government whether or not they are shown as benefitting from central service functions; a copy of the Comprehensive Annual Financial Report (or a copy of the Executive Budget if budgeted costs are being proposed) to support the allowable costs of each central service activity included in the plan; and, a certification (see subsection 4.) that the plan was prepared in accordance with this Part, contains only allowable costs, and was prepared in a manner that treated similar costs consistently among the various Federal awards and between Federal and non-Federal awards/activities. . . ." Cause The County had not developed a system of internal controls that would have ensured compliance with the Allowable Costs/Cost Principles compliance requirement. Effect The failure to establish an effective internal control system enabled material noncompliance to go undetected. Noncompliance with the grant agreement and the Allowable Costs/Cost Principles compliance requirement could have resulted in the loss of federal funds to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the County's management establish a system of internal controls to ensure compliance and comply with the grant agreement and the Allowable Costs/Cost Principles compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
FINDING 2019-003 Contact Person Responsible for Corrective Action: Michael J. Hamann Contact Phone Number: (574) 235-9668 Views of Responsible Official: We concur with the audit finding with respect to including an organizational chart and an allocated cost pool for Building Use in the Cost Allocation Plan. Description of Corrective Action Plan: Saint Joseph County uses a very good and reputable consulting firm to prepare its Annual Countywide IV-D Cost Allocation plan. The County Auditor will work with the consulting firm to include an organizational chart and the allocated cost pool for Building Use in all future reports. Anticipated Completion Date: December 31, 2020
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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