Crawford County

U.S. Department of the Treasury 2024-005 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – Federal Assistance Listing Number 21.027 Condition: We noted two covered transactions where the debarment and suspension status of the vendor was not verified by the County. Criteria: The CSLFRF grant award states the regulations contained in 2 CFR 180 regarding debarment and suspension are applicable to this award. Cause: The County did not correctly understand the requirements to verify the debarment and suspension status of a vendor for covered transactions. Effect: Disbursement of grant funds to a suspended or debarred vendor could occur, which would be in violation of the grant award. Context: A total of eleven disbursements was selected for testing, which was a statistically valid sample. The auditor verified on SAM.gov that the vendors for the two covered transactions were not debarred or suspended. Therefore, there are no questioned costs. Recommendation: The debarment and suspension status of all vendors for which grant fund disbursements exceed $25,000 should be verified on SAM.gov prior to the disbursement of grant funds. Views of Responsible Officials and Planned Corrective Actions: Management did not correctly understand this requirement. The County will verify the debarment and suspension status of all vendors for which grant fund disbursements exceed $25,000 on SAM.gov prior to the disbursement of grant funds.

COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – Federal Assistance Listing Number 20.027 Condition: We noted one disbursement of grant funds supported by a claim form with only one source of approval. Another disbursement was supported by a claim form with only one source of approval and the check issued was signed by only one authorized signer. Criteria: 2 CFR 200.303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award. Also, CFR 200.302(b)(3) states the financial management system of each non-Federal entity must provide records that identify adequately, among other things, proper authorizations. Cause: Internal controls over cash disbursements were overridden. The County’s policy is to require two signatures on all checks, as well as a completed claim form which is approved by a department head, the county clerk, and a member of the claims committee. Effect: Unauthorized or improper use of grant funds could occur. Context: A total of thirteen disbursements was selected for testing, which was 100% of the population. The use of grant funds for the purpose of these disbursements was previously approved by the county board. Therefore, there are no questioned costs. Recommendation: Management should follow the internal control policies in effect for the disbursement of other County funds in the disbursement of CSLFRF grant funds. Views of Responsible Officials and Planned Corrective Actions: Management will follow controls implemented over approving claim forms and signing checks for other County disbursements for CSLFRF grant disbursements.

COVID-19 – Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) – Federal Assistance Listing Number 20.027 Condition: We noted three covered transactions where the debarment and suspension status of the vendor was not verified by the County. Criteria: The CSLFRF grant award states the regulations contained in 2 CFR 180 regarding debarment and suspension are applicable to this award. Cause: The County did not have any internal controls in place to verify the debarment and suspension status of a vendor for covered transactions. Effect: Disbursement of grant funds to a suspended or debarred vendor could occur, which would be in violation of the grant award. Context: A total of thirteen disbursements was selected for testing, which was 100% of the population. The auditor verified on SAM.gov that the vendors for the three covered transactions were not debarred or suspended. Therefore, there are no questioned costs. Recommendation: The debarment and suspension status of all vendors for which grant fund disbursements exceed $25,000 should be verified on SAM.gov prior to the disbursement of grant funds. Views of Responsible Officials and Planned Corrective Actions: Management was not aware of this requirement. The County will verify the debarment and suspension status of all vendors for which grant fund disbursements exceed $25,000 on SAM.gov prior to the disbursement of grant funds.

Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) ? CFDA #93.323 2021-004 Noncompliance with Allowable Activities Requirements Condition: ELC hours as reported on employee timesheets or payroll registers did not agree to the hours claimed on the ELC grant reimbursement certification form in two instances. Criteria: 2 CFR 200.430(i) states that charges to Federal awards for salaries and wages must be based on records that adequately reflect the work performed. Cause: The hours and amounts reported on the ELC grant reimbursement certification form were not reviewed for accuracy. Effect: ELC payroll costs may be improperly claimed if timesheets do not support the amounts reported on the reimbursement certification form. Context: In a sample of 34 ELC monthly payroll amounts reported on the reimbursement certification forms, we identified 2 instances where the hours reported were not supported by the employee?s timesheet or payroll register. In the first case, the employee?s timesheet reported 11.25 hours for ELC and that amount was charged to the grant. However, the employee was only paid for 6 hours upon review of the applicable payroll register. In the second case, an additional 12 hours reported as environmental health on the employee?s timesheet was added to the employee?s ELC hours. The amount of the errors was $415 out of a sample of $38,870. The population of the ELC payroll was $233,812. Our sample was a statistically valid sample. Recommendation: Management should assess why the controls in place failed to identify the reporting errors and implement additional review processes to mitigate errors. Views of Responsible Officials and Planned Corrective Actions: Management will implement additional controls over reviewing and approving payroll allocations.

DEPARTMENT OF TREASURY Coronavirus Relief Fund ? CFDA #21.019 2020-003 Noncompliance with Allowable Activities Requirements Condition: The County has inadequate controls over allocating and documenting Coronavirus Relief Fund payroll costs. Criteria: Internal controls should be in place to provide reasonable assurance that Coronavirus Relief Fund payroll costs are properly allocated and not reimbursed by another federal or state grant. Effect: Coronavirus Relief Fund payroll costs may be claimed inappropriately if the County also receives reimbursement for those same payroll costs from another federal or state grant. Context: In a sample of 44 Coronavirus Relief Fund payroll disbursements (specifically, the Local Coronavirus Urgent Remediation Emergency Support Program or Local CURE Program), we identified 2 instances where 100% of an employee?s wages were claimed for reimbursement but upon review of the employee?s timesheet their time was allocated to programs where other federal or state grant reimbursements are received. This was the result of a manual input error. The amount of the error was $2,144 out of a sample of $60,576. The population of Coronavirus Relief Fund payroll is $536,603. Our sample was a statistically valid sample. Recommendation: Management should assess why the controls in place failed to identify an allocation error and implement additional review processes to mitigate errors. Views of Responsible Officials and Planned Corrective Actions: Management will implement additional controls over reviewing and approving Coronavirus Relief Fund payroll allocations.