COUNTY OF IROQUOISLocal Government

Federal Agency: U.S. Department of Treasury Federal Program Name: COVID 19-Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201; FY24 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned Costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total accumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested, which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG was not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2023-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: COVID 19-Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201; FY24 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or Specific Requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include disbursements be reviewed, and this review should be documented. Condition: We noted the supporting documentation for a grant-related disbursement included an invoice that was reviewed and approved by the department head but did not include the board chairman’s signature but was paid by the treasurer’s office. Questioned Costs: None Context: This issue was noted in 1 of 8 disbursements tested for this program. Cause: Oversight Effect: Lack of proper documented review prior to payment can allow an inappropriate expenditure to occur. Repeat Finding: No Recommendation: We recommend the County strengthen internal controls over the review process of disbursements. This can include ensuring it is clear what documentation is required to support approval. Views of Responsible Officials: There is no disagreement with this finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: SLFRP4201 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Uniform Grant Guidance (2 CFR 200.329) requires non-federal entities submit performance reports required by Federal award and that the data accumulated and summarized is in accordance with the required or stated criteria and methodology. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail and amounts obligated should reflect total procurement amounts awarded. Condition: While the correct expenditures were reported on the schedule of expenditures of federal awards, the performance report filed during the year did not accurately report project details. Current period expenditures and obligations should have reported amounts expended and procurement amounts awarded during the reporting period and cumulative expenditure and obligations should have reported amounts expended and procurement amounts awarded from the start of the grant through the end of the reporting period. Questioned costs: None Context: 1 of 1 tested for reporting documentation. Cause: Total current period expenditures and obligations and total cumulated expenditures and obligations were not reconciled to the expenditure detail and procurement award detail. Prior period performance report overstated current period expenditures and obligations. These errors were corrected through current period performance report tested which causes current period expenditures and obligations to be understated. Effect: Cost could be disallowed as UGG not followed. Repeat Finding: The finding is a repeat of a finding in the prior year. The prior year finding number was 2022-005. Recommendation: We recommend the County perform a reconciliation of the project details reported to the expenditure detail and procurement amounts awarded detail used to support the SEFA, and these reconciliations be reviewed, to ensure accuracy and completeness of the reporting. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271; 2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318, 2 CFR 200.319, 2 CFR 200.324 and 2 CFR 180.220) requires a non-federal entity to maintain records sufficient to detail the history of procurement, the providing of full and open competition, the performing of cost or price analysis, and prohibits the non-federal entity to contract or make subawards to parties that are suspended or debarred. These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, how full and open competition was provided, the cost or price analysis performed, and verification the vendor is not suspended or debarred through the SAMs exclusion list, collecting of certification from the entity, or by adding a clause or condition to the covered transaction with the entity. Condition: Procurement methods for certain federal award purchases were not adequately documented and the County did not verify the vendor was not suspended or debarred prior to entering into the transactions. Questioned costs: None Context: 3 of 5 tested for procurement documentation and 6 of 6 tested for suspension and debarment documentation. Cause: Lack of documentation retained over procurement rationale or cost analysis and lack of knowledge on suspension and debarment policy. Effect: Purchases are not properly documented to meet the Federal procurement requirements. CLA was able to determine the vendors were not suspended or debarred. Repeat Finding: This finding is a repeat of a finding in the prior year on a different program. Prior year finding number was 2021-003. Recommendation: We recommend the County carefully review federal procurement requirements for proper documentation needed. The County should consider use of a Federal procurement checklist. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: 1505-0271; 2021 Award Period: March 3, 2021 through December 31, 2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.303) requires non-federal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include ensuring the reported projects and expenditures accurately reflect what is reported in the expenditure detail. Condition: The expenditure report filed during the year did not accurately report project details, including amounts expended, subaward types as contractors and grants, loans, transfers, or direct payments to individuals, subrecipient entity types as contractors, beneficiaries, or subrecipients, and amounts of lost revenue elected to be used for the period required. In addition, there is no formal documentation of the review being completed by the ARPA committee in accordance with the County?s internal control procedures. Questioned costs: None Context: The County incorrectly reported current projects and expenditures in 1 of 1 reports tested. Cause: Reported projects and expenditures were based on projects and projects cost that had been approved by resolution by the ARPA committee and County Board, and not what had actually been incurred through the reporting date. Subaward and subrecipient types were not clearly distinguished and lost revenue amounts taken were not indicated. These details were inaccurately reported due to unclear instructions. There was no documentation of review and approval by a department head or the ARPA committee. Effect: While correct expenditures were reported on the schedule of expenditures of federal award for the year ended November 30, 2022, the interim period reporting for the period ended March 31, 2022 included obligations in the amount reported as expended, This could result in costs being questioned interperiod Repeat Finding: No Recommendation: We recommend the County strengthen its review procedures over reports and ensure the review is documented. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases (Contract Tracing and Response grants); Support of Immunization Initiative-Focusing on Childhood Vaccination Programs (Mass Vacation) Assistance Listing Number: 93.323 and 93.268 Federal Award Identification Number and Year: 6NU50CK000559-01-08 Year 2020 and 2021; NH23IP922637 Year 2021 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H; 28180539J; 15080638I-1 Award Period: June 1, 2020 through March 31, 2022; July 1, 2022 through December 31, 2022; December 1, 2020 through December 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. A lump sum overtime payment was made for built up unrecorded/unpaid hours with no supporting documentation regarding what days the hours were worked. Questioned costs: $777.72 Contract Tracing; $194.43 Mass Vaccination; $12,573.77 Response Context: All overtime charged to the grants by the Health Department Administrator Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: This finding is a repeat of a finding in the prior year. The prior year finding number was 2021-004. Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing Number: 93.323 Federal Award Identification Number and Year: 6NU50CK000559-01-08, Year 2020 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H Award Period: June 1, 2020 through March 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.318) requires a non-federal entity to maintain records sufficient to detail the history of procurement. These records will include the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. This may include documentation a vendor is a sole source provider or an emergency purchase. Condition: Procurement methods for certain federal award purchases were not adequately documented. Questioned costs: None Context: 5 of 5 procurement transactions. Cause: Lack of knowledge of the requirements. Effect: Emergency purchases are not properly documented to meet the Federal procurement requirements. Repeat Finding: No Recommendation: We recommend the County carefully review procurement requirements and maintain proper documentation of procurement methods relative to costs allocated to federal programs. This may include documentation that a sole source provider or an emergency purchase. Views of responsible officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing Number: 93.323 Federal Award Identification Number and Year: 6NU50CK000559-01-08, Year 2020 Pass-Through Agency: Illinois Department of Public Health Pass-Through Number: 05180138H Award Period: June 1, 2020 through March 31, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Uniform Grant Guidance (2 CFR 200.430) requires a non-federal entity to maintain sufficient time and effort records for personal services to accurately reflect work performed. Condition: Overtime was being charged to the program on days that vacation and sick time was used. Questioned costs: None Context: 1 of 40 tested. Cause: Time cards did not provide sufficient detail to determine which days in the period were being charged for overtime, and appears overtime was charged during paid time off for 1 of 40 payroll transactions tested. Effect: Lack of proper time and effort reporting can lead to unallowable costs. Repeat Finding: No Recommendation: We recommend the County review time and effort records to ensure overtime is not charged to Federal grants on days in which vacation and sick time is used. More detailed reporting of the days in which the vacation and sick days are used and the overtime days would assist with this process. Views of responsible officials: There is no disagreement with the audit finding.