Green Lake CountyLocal Government

2024-005 Procurement, Suspension and Debarment Federal Assistance Listing Numbers – 21.027 Federal Agency – Department of Treasury Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period – 03/31/2021 through 12/31/2024, 10/01/2020 through 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Compliance Requirement: Procurement, Suspension and Debarment Condition: The County did not follow its procurement policy. Additionally, the procurement policy in place does not meet UG requirements, which includes having a policy on suspension and debarment verification. Criteria: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The nonfederal entity must maintain records 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. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. 2 CFR 200 states that nonfederal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All nonprocurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Unknown Context: During testing, it was noted that the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Furthermore, the County did not retain supporting documentation for the procurement method selected. All six of the transactions tested did not follow the required procedures in place. Cause: The County has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Effect: The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: This is a repeat finding of 2023-004. Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Views of Responsible Officials: There is no disagreement with the finding. The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants.

2024-006 Review of Claim Forms and Expenditure Reconciliations Federal Assistance Listing Numbers – 93.778 Federal Agency –Department of Health and Human Services Federal Program Title – Medicaid Cluster State ID Numbers – Various State Program Title - Various Award Period – 01/01/2024-12/31/2024 Type of Finding: Material Weakness in Internal Control Over Compliance Compliance Requirement: Reporting, Cash Management Condition: The County did not perform review procedures over claims prior to submission or over monthly expenditure reconciliations. Criteria: Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. Review of claims and expenditure reconciliations is an important control over compliance to ensure reports are properly prepared and agree with the County’s actual activity. Questioned Costs: None Context: During reporting testing, it was noted that the County does not have review process in place for reporting or cash management. Cause: There was no review over the monthly claims and monthly expenditures reconciliations prior to submission. Effect: Unallowed costs could be claimed, or costs could be double claimed. Repeat Finding: This is a repeat finding of 2023-005. Recommendation: We recommend that there is an appropriate reviewer of each claim and expenditure reconciliation. Views of Responsible Officials: There is no disagreement with the finding. The County is working to implement review and approval procedures after experiencing significant turnover and transition.

Federal Assistance Listing Numbers – 21.027 Federal Agency – Department of Treasury Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period – 03/31/2021 through 12/31/2024, 10/01/2020 through 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Compliance Requirement: Procurement, Suspension and Debarment Condition: The County did not follow its procurement policy. Additionally, the procurement policy in place does not meet UG requirements, which includes having a policy on suspension and debarment verification. Criteria: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must maintain records 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. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. 2 CFR 200 states that non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Unknown Context: During testing, it was noted that the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Furthermore, the County did not retain supporting documentation for the procurement method selected. All six of the transactions tested did not follow the required procedures in place. Cause: The County has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Effect: The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: This is a repeat finding of 2022-004. Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Views of Responsible Officials: There is no disagreement with the finding. The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants.

Federal Assistance Listing Numbers – 93.778 Federal Agency –Department of Health and Human Services Federal Program Title – Medicaid Cluster State ID Numbers – Various State Program Title - Various Award Period – 01/01/2023-12/31/2023 Type of Finding: Material Weakness in Internal Control Over Compliance Compliance Requirement: Reporting, Cash Management Condition: The County did not perform review procedures over claims prior to submission or over monthly expenditure reconciliations. Criteria: Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. Review of claims and expenditure reconciliations is an important control over compliance to ensure reports are properly prepared and agree with the County’s actual activity. Questioned Costs: None Context: During reporting testing, it was noted that the County does not have review process in place for reporting or cash management. Cause: There was no review over the monthly claims and monthly expenditures reconciliations prior to submission. Effect: Unallowed costs could be claimed, or costs could be double claimed. Repeat Finding: This is a repeat finding of 2022-006. Recommendation: We recommend that there is an appropriate reviewer of each claim and expenditure reconciliation. Views of Responsible Officials: There is no disagreement with the finding. The County is working to implement review and approval procedures after experiencing significant turnover and transition.

2022-003 Performance Reports Federal Assistance Listing Numbers – 21.027 Federal Agency – Department of Treasury Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period – 03/31/2021 through 12/31/2024 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Compliance Requirement: Reporting Condition: The County did not perform review procedures over performance reports prior to submission and did not have appropriate support retained for costs included on the performance report. Criteria: Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. Review of performance reports is an important control over compliance to ensure reports are properly prepared and agree with the County’s actual activity. Questioned Costs: None Context: During reporting testing, it was noted that the County does not have review process in place for reporting. Cause: There was no review over the annual performance report prior to submission. Effect: Unallowed costs could be claimed, or costs could be double claimed. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that there is an appropriate reviewer of each performance report. Views of Responsible Officials: There is no disagreement with the finding. The County is working to implement review and approval procedures after experiencing significant turnover and transition.

2022-004 Procurement, Suspension and Debarment Federal Assistance Listing Numbers – 21.027, 93.323 Federal Agency – Department of Treasury, Department of Health and Human Services Federal Program Title – COVID-19 Coronavirus State and Local Fiscal Recovery Funds, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Award Period – 03/31/2021 through 12/31/2024, 10/01/2020 through 12/31/2023 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matter Compliance Requirement: Procurement, Suspension and Debarment Condition: The County did not follow its procurement policy. Additionally, the procurement policy in place does not meet UG requirements, which includes having a policy on suspension and debarment verification. Criteria: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must maintain records 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. Further, the method of procurement, whether informal or formal, must follow the County’s written procurement policy on approval thresholds and controls. 2 CFR 200 states that non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Questioned Costs: Unknown Context: During testing, it was noted that the County does have a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Furthermore, the County did not retain supporting documentation for the procurement method selected. Cause: The County has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the County have a policy that covers suspension and debarment. Effect: The County is not in compliance with procurement or suspension and debarment requirements. Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. Vendors may be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Views of Responsible Officials: There is no disagreement with the finding. The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants.

2022-006 Review of Claim Forms and Expenditure Reconciliations Federal Assistance Listing Numbers –93.323, 93.778 Federal Agency –Department of Health and Human Services Federal Program Title –COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), Medicaid Cluster State ID Numbers – Various State Program Title - Various Award Period – 10/01/2020 through 12/31/2023, 01/01/2022-12/31/2022 Type of Finding: Material Weakness in Internal Control Over Compliance Compliance Requirement: Reporting, Cash Management Condition: The County did not perform review procedures over claims prior to submission or over monthly expenditure reconciliations. Criteria: Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. Review of claims and expenditures reconciliations is an important control over compliance to ensure reports are properly prepared and agree with the County’s actual activity. Questioned Costs: None Context: During reporting testing, it was noted that the County does not have review process in place for reporting or cash management. Cause: There was no review over the monthly claims and monthly expenditures reconciliations prior to submission. Effect: Unallowed costs could be claimed, or costs could be double claimed. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that there is an appropriate reviewer of each claims and expenditure reconciliation. Views of Responsible Officials: There is no disagreement with the finding. The County is working to implement review and approval procedures after experiencing significant turnover and transition.

2020-004 Financial Reporting for Federal and State Awards Federal Agency: All Federal Program Title: All Assistance Listing Number: All State Agency: All State Program: All State ID: All Pass-through Agency: All Pass-through Number(s): All Award Period: January 1, 2020 through December 31, 2020 Type of Finding: Significant deficiency in internal control over compliance Criteria Having staff with expertise in federal and state financial reporting prepare the County?s single audit report is an internal control intended to prevent, detect and correct a potential misstatement in the schedules of expenditures of federal and state awards, or accompanying notes to the schedule. Condition Section 200.510 of the Uniform Guidance and Section 2.1.6 of the main document of the State Single Audit Guidelines require the County to prepare appropriate financial statements, including the schedules of expenditures of federal and state awards. While the current staff of the County maintains financial records supporting amounts reported in the schedules of expenditures of federal and state awards, the County contracts with CLA to compile the data from these records and assist in the preparation of the single audit report for the County. Questioned Costs None. Context While performing audit procedures, it was noted that management does not have internal controls in place to prepare the schedule of expenditures of federal awards and the schedule of expenditures of state awards in accordance with U.S. GAAP, Uniform Guidance, and the State Single Audit Guidelines. Cause The additional costs associated with hiring staff sufficiently experienced to prepare the County?s single audit report, including the additional training time, outweigh the derived benefits. Effect The County could receive federal or state grant awards which are not included in the accompanying schedules of expenditures of federal and state awards. Repeat Finding Repeat of Finding 2019-003. Recommendation We recommend County personnel continue reviewing the County?s single audit report. While it may not be cost beneficial to hire additional staff to prepare these items, a thorough review of this information by appropriate staff of the County is necessary to ensure all federal and state financial assistance programs are properly reported in the County?s single audit report. View of Responsible Officials There is no disagreement with this finding.

COVID-19 Coronavirus Relief Fund Reporting Federal Agency: U.S. Department of the Treasury Federal Program Title: Coronavirus Relief Fund Assistance Listing Number: 21.019 Pass-through Agency: Wisconsin Department of Administration Pass-Through Number: Unknown Award Period: March 1, 2020 through December 31, 2020 Type of Finding: Significant deficiency in internal control over compliance and other matter Criteria 2 CFR 200.302 requires that "The financial management system of each non-Federal entity must provide for the following: (1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the CFDA title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any." Grant claims filed by the County to the various granting agencies must be accurate, reconcile to the County general ledger system, and for cost-reimbursement grants, represent costs incurred. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. Segregation of duties is an internal control intended to prevent or decrease the occurrence of errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of a transaction. Condition The County?s general ledger did not specifically identify all accounts where federal expenditures were recorded. A separate payroll document was used to track expenses and was subsequently used to claim on the Routes to Recovery portion of the Coronavirus Relief Funds. There was no final formal review of the Routes to Recovery reports and claims for reimbursement in comparison to the general ledger. Questioned Costs None. Context While performing audit procedures, it was noted that project codes and unique expenditure account numbers were not always used for the Routes to Recovery portion of the Coronavirus Relief Funds. The County identified unsupported costs on the Routes to Recovery claims when pulling documentation for a sample of transactions selected by the auditors for compliance testing. It was also noted that there was not a final formal review done comparing the expenses per the general ledger to the claims. Cause The review of the data in the shared document prior to submitting the claim to WI Department of Administration did not identify that costs claimed did not agree to the general ledger totals. Effect The County could over- or under-report certain items for reimbursement. Repeat Finding No. Recommendation We recommend the County review its processes and implement controls to address nonroutine grant situations to ensure that account coding is properly set up and any expenditures incurred prior to the set up are reclassified to the unique expenditure account. Claims, in particular final claims, should be formally reviewed and compared to the balances in these unique expenditure accounts. View of Responsible Officials There is no disagreement with this finding.

2020-006 Procurement and Suspension and Debarment Federal Agency: U.S. Department of Transportation Federal Program Title: Recreational Trails Program Assistance Listing Number: 20.219 Pass-through Agency: Wisconsin Department of Natural Resources Pass-Through Number: CF RTA77215 F Award Period: April 1, 2016 through June 30, 2021 Type of Finding: Material Weakness in internal control over compliance and other matter Criteria 2 CFR 200.320(a)(2)(ii) requires that "The non-Federal entity is responsible for determining an appropriate simplified acquisition threshold based on internal controls, an evaluation of risk and its documented procurement procedures which must not exceed the threshold established in the FAR. When applicable, a lower simplified acquisition threshold used by the non-Federal entity must be authorized or not prohibited under State, local, or tribal laws or regulations." When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition The County relied upon a vendor to monitor the procurement process. The County did not follow controls related to ensuring suspension and debarment status was verified prior to entering into contract with vendors. Questioned Costs None. Context While performing compliance procedures, it was noted that the County did not follow adopted policies for procurement and suspension and debarment. In one instance, the County relied on a vendor to handle the bid process and did not monitor or review the process. In another instance, the purchase was made under the proposal method and the County did not monitor or review the process. Further, there was no evidence supporting that the County reviewed for suspension and debarment. Cause The County relied upon a vendor to monitor the procurement process. The County did not follow controls related to ensuring suspension and debarment status was verified prior to entering into contract with vendors. Effect Contracts for construction, nonconstruction related procurements, and those over the simplified acquisition threshold may not be in compliance with the Uniform Guidance. The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Repeat Finding No. Recommendation We recommend that the County reviews their comprehensive financial policy and procedure manual that complies with the Uniform Guidance with all department heads. We recommend the District consider implementing approval of procurement contracts by the board, administrator or other individuals so that another individual is reviewing competition and selecting the winner, reviewing documentation for how each one is chosen and that there was open competition in accordance with Uniform Guidance requirements. We recommend the County use sam.gov or the ELPS listing to review vendors at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. View of Responsible Officials There is no disagreement with the finding.

FINDING NO. UNIFORM GUIDANCE AND STATE SINGLE AUDIT GUIDELINES FINDINGS 2019-003 Financial Reporting for Federal and State Awards Federal CFDA - All State IDs ? All Federal Agency: All Federal Program Title: All CFDA Number: All Pass-Through Agency: All Pass-Through Numbers: All Award Period: All Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Having staff with expertise in federal and state financial reporting prepare the County?s single audit report is an internal control intended to prevent, detect and correct a potential misstatement in the schedules of expenditures of federal and state awards, or accompanying notes to the schedule. Condition: Uniform Guidance and the State Single Audit Guidelines require the County to prepare appropriate financial statements, including the schedules of expenditures of federal and state awards. While the current staff of the County maintains financial records supporting amounts reported in the schedules of expenditures of federal and state awards, the County contracts with CLA to compile the data from these records and assist in the preparation of the single audit report for the County. Questioned Costs: None Context: While performing audit procedures, it was noted that management does not have a tracking method in place to provide reasonable assurance that the schedule of expenditures of federal awards and the schedule of expenditures of state awards are prepared in accordance with U.S. GAAP and Uniform Guidance. Cause: The additional costs associated with hiring staff sufficiently experienced to prepare the County?s single audit report, including the additional training time, outweigh the derived benefits. Effect: The County could receive federal or state grant awards which are not included in the accompanying Schedules of Expenditures of Federal and State Awards. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2018-003. Recommendation: We recommend County personnel continue reviewing the County?s single audit report. While it may not be cost beneficial to hire additional staff to prepare these items, a thorough review of this information by appropriate staff of the County is necessary to ensure all federal and state financial assistance programs are properly reported in the County?s single audit report. Views of Responsible Officials: There is no disagreement with the audit finding. Please refer to the management response in the County?s corrective action plan.

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