Brown County, WisconsinLocal Government

2023-002 Suspension & Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Numbers: 155811 and 2021-VO-A/VO-01-17452 Federal Award Identification Number and Year: SLFRF1158; 2020 Award Periods: March 1, 2020 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement 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 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 While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs None. Context While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause The County’s current procurement policy does not follow Uniform Guidance. Effect The County is not in compliance with suspension and debarment requirements. 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 Yes Recommendation We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials The County has implemented a new purchasing policy effective January 2024 that is in compliance with UGG.

Criteria or Specific Requirement: 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 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: While the County has policies and procedures relating to suspension and debarment, they do not meet Uniform Guidance requirements. Questioned Costs: None. Context: While performing compliance procedures, it was noted that suspension and debarment procedures were not completed for all vendors meeting the requirements. Subsequent client procedures concluded that none of the contractors or vendors were suspended or debarred. Cause: The County?s current procurement policy does not follow Uniform Guidance. Effect: The County is not in compliance with suspension and debarment requirements. 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: No Recommendation: We recommend the County review and update procurement policies for the entire County to include suspension and debarment to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials: There is no disagreement with the finding.

U.S. Department of Health and Human Services Provider Relief Funds Assistance Listing Number ? 93.498 Federal Award Identification Number and Year: PRF20200001 and Year 2020 Award Period: 4/10/20 ? 12/31/21 Type of Finding Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement Uniform Guidance requires the reporting of costs or activities as the basis for making payments to providers. The County should have control activities for ensuring accurate reporting. Condition It was noted that there was a lack of independent review of the Provider Relief Fund reports submitted to the U.S. Treasury by someone that did not prepare the report. Context While performing audit procedures, it was noted that the County does not have policies in place to ensure there is an independent review of reports. Questioned Costs: None. Cause The County does not have a system of internal controls in place to ensure reports are reviewed by an independent person who did not prepare the report. Repeat Finding: N/A Effect Grant expenditures could be over or under-reported and not detected by County personnel. Recommendation We recommend the County implement procedures to ensure that someone knowledgeable of the grant requirements reviews the report prior to submission. Views of Responsible Officials The County agrees with this finding.