County of Dane

Finding 2023-002 Repeat of Finding 2022-002 Assistance Listing and State ID Numbers: 93.658, 93.667, 435.000561/435.000681, 435.560100, 437.3561 / 437.3681 Program Titles: Foster Care - Title IV-E, Social Services Block Grant, Basic County Allocation/State/County Match, ADRC Base GPR Reimbursement, CW Children and Families Allocation Award Numbers / Year: See State ID Numbers / 2023 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entities: Wisconsin Department of Children and Families Wisconsin Department of Health Services Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of GEARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. One of the three GEARS and SPARC monthly reports tested was not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place during the period of January 2023 to September 2023 that required an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should continue the internal control review process that was implemented in September 2023 to ensure that reports are complete and accurate before submissions to state agencies are completed. Management's Response: In September 2023, a review process was established and implemented starting with the August Claim to ensure that required reports are reviewed by someone other than the preparer of the reports prior to submission.

Finding 2023-003 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR section 200.332(a) requires all subaward contracts contain the required information as documented in 2 CFR section 200.332(a)(1) in order for subrecipients to comply with the award agreement. Condition/Context: Both of the two subawards selected for testing did not contain the required elements found in 2 CFR Part 200.332(a). The sample selected was not statistically valid. Cause: The County's subaward agreement template which contains the required elements was not utilized for this program. Effect: The subaward agreement contracts did not contain the required information; therefore, the subrecipients may not have obtained the appropriate grant information needed to comply with the terms and conditions of the award. Questioned Costs: None noted. Recommendation: We recommend utilizing the County's subaward agreement template to ensure the required information is communicated to subrecipients. In addition, the County should consider providing the required information to the subrecipients retrospectively. Management's Response: The County will create Subrecipient Agreements for all providers that are identified as pass-through entities and amend their contracts to add the agreement to existing contracts.

Finding 2023-004 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance (ERA) Award Number / Year: 1505-0270 / 2023 Federal Agency: U.S. Department of Treasury Pass-Through Entity: Not applicable Criteria: 2 CFR Part 200.329(b) and ERA Reporting Guidance requires quarterly reporting to the Treasury portal contain all expenditures and obligations to be clearly identified by type including subawards, contracts, direct payments, or beneficiaries. The required information includes identification of subrecipients which are entities that receive a subaward from a recipient to carry out the purposes (program or project) of the ERA award on behalf of the recipient. Subrecipient relationships require additional monitoring and compliance steps. The direct recipient (the County) is responsible for determining if an entity is considered to be a subrecipient. Condition/Context: Both of the two reports selected for testing contained a contractor that was incorrectly reported as a subaward. Our sample was not statistically valid. Cause: The County did not have internal controls in place requiring an independent person with an understanding of the subrecipient terminology and classification to review the report prior to submission to the U.S. Department of Treasury. Effect: The report was submitted with subrecipient misclassifications. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes in place over completeness and accuracy of reports before submissions to federal agencies are completed. Management's Response: Effective with the 2024 third quarter reporting, the contractor incorrectly reported as a subaward with Treasury was corrected.

Finding 2022-002 Assistance Listing and 93.563, 437.7502, 435.000377, 435.000561/435.000681, State ID Numbers: 435.000471/435.000877, and 437.3410 Program Titles: Child Support Enforcement, CS State GPR/PR Funding Allocation, Children's COP, Basic County Allocation/State/County Match, CLTS Autism GPR/CLTS Waiver CWA Admin GPR, and JJ Community Intervention Program Award Numbers / Year: See State ID Numbers / 2022 Pass-Through Entity: Wisconsin Department of Children and Families Criteria: The Uniform Guidance and State Single Audit Guidelines require that local entities receiving federal and state awards establish and maintain internal control designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. The Uniform Guidance and State Single Audit Guidelines further require auditors to obtain an understanding of the local entity's internal control over federal and state programs. To minimize the risk of errors, internal controls should be in place for all program compliance requirements, including the preparation and submission reports, which should be reviewed and approved by a responsible party other than the original preparer. Condition/Context: We selected three monthly submissions of CARS and SPARC reports across multiple programs received by the Wisconsin Department of Human Services and the Wisconsin Department of Children and Families. All three of the CARS and SPARC reports tested were not reviewed by an independent person before submission for reimbursement. Our sample was not statistically valid. Cause: The County did not have internal control procedures in place requiring an independent person to review the reports before submission to ensure the reports were accurately and timely submitted. Effect: Reports submitted could contain errors. Questioned Costs: None noted. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes over completeness and accuracy of reports in place before submissions to state agencies are completed. Management's Response: A review process will be implemented with September 2023 reports.

Finding 2022-005 Assistance Listing and State ID Numbers: 93.563 and 437.7502 Program Titles: Child Support Enforcement and CS State GPR/PR Funding Allocation Award Number / Year: 437.7502 / 2022 Pass-Through Entity: Wisconsin Department of Children and Families Criteria: 2 CFR section 200.430(i)(1)(viii)(C) requires the system of internal controls to include processes to conduct after-the-fact reviews of interim charges made to federal awards based on budget estimates used to charge salaries and wages. All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated. Condition/Context: One of the thirty-seven payroll transactions tested was more than actual costs incurred due to incorrect payroll information being used to calculate the payroll expense. Our sample was not statistically valid. Cause: The payroll cost allocation spreadsheet was not properly reviewed against the payroll system. Effect: Payroll costs were overcharged to the award. Questioned Costs: Questioned costs of $269 related to excess payroll charges are reported in accordance with the thresholds of the Wisconsin State Single Audit Guidelines and relate to expenditures funded by both federal and state sources, specifically 93.563 Child Support Enforcement and 437.7502 CS State GPR/PR Funding Allocation. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes over payroll information used to calculate amounts claimed for grant reimbursement. Management's Response: The reimbursement reports prepared by the Clerk of Courts will be reviewed by a person other than the preparer to ensure accuracy. The review will be completed before the reimbursement request is submitted to Child Support.

Finding 2021-002 Assistance Listing Number: 21.023 Program Title: COVID-19 Emergency Rental Assistance Program Award Number / Year: ERA1, ERA2 / 2021 Pass-Through Entity: Not applicable Criteria: 2 CFR section 200.303 requires grantees to establish and maintain effective internal controls over federal awards, including the preparation of required program reports. Condition/Context: We selected a sample of four reports required to be submitted by the County in relation to the Emergency Rental Assistance Program. These consisted of monthly and quarterly reports. We noted that the reports were not reviewed by someone other than the preparer prior to submission. Our sample was not statistically valid. Cause: The County did not have personnel identified to complete review of the reports prior to submission. Effect: There is a higher likelihood that the reports could contain errors. Questioned Costs: None noted Recommendation: We recommend that the County implement a review process for required reports on a prospective basis. Management's Response: A review process will be established and implemented to ensure that the required reports are reviewed by someone other than the preparer of the reports prior to submission.

Program Federal ID Number and Title: 14.218 - CDBG Entitlement Grants Cluster - Community Development Block Grant/Entitlement Grant Federal Grantor: U.S. Department of Housing and Urban Development Award Number: B-17-UC-55-003, B-18-UC-55-003, B-19-UC-55-003 Award Year: 2017, 2018, 2019 Criteria: To ensure internal control over payment of expenditures, there should be an independent review and approval of all timesheets for payroll that is documented. In addition, Uniform Guidance requires employees who have been allocated to more than one grant to be reviewed for accuracy based on actual time worked. Condition/Context: One (1) out of four (4) employees sampled for testing did not have original approved timecards. Furthermore, there was no evidence provided to support the employee allocation between CDBG and HOME. The county did provide evidence that the employee was not charged more than 100% to the program and based on prior allocations appeared to be allocated appropriately. Additionally, payroll prior to being disbursed goes through the controller?s office for final review. The sample was not statistically valid. Cause: Payroll is reviewed by the Office of Economic and Workforce Development Director. Director payroll approval is reviewed during cash draw submissions by the controller?s office. The previous Director who is no longer with the county maintained his timecards electronically, which were lost and/or unable to be provided for the audit. Effect: The amounts charged to the Federal grants may not reflect actual distribution of costs. Questioned Costs: Unable to be determined. Recommendation: We recommend the County review its procedures for documenting time and effort to ensure that records are preserved in accordance with retention requirements. Management?s Response: The staff responsible for oversight of CDBG/HOME activities log their time spent on program activities on the required time sheets. These time sheets are reviewed and tracked by the staff?s supervisor and employee costs for time spent on the CDBG/HOME programs, based on the timesheets, are submitted annually to HUD to claim as program administration costs. As noted, in February of 2020, the Director of the Office of Economic and Workforce Development passed away. No records could be found of the timesheets he would have filed to comply with the protocol outlined in OMB Circular to claim his time spent on CDBG/HOME activities. In addition, in 2020, administration of the CDBG/HOME programs was reorganized into a new division within the Dane County Department of Human Services, the Housing Access and Affordability Division (HAA). As a result, CDBG staff are currently under the supervision of the Division Administrator for HAA. The Division Administrator is aware of the adjustments that need to be made to comply with time reporting and will work with staff to implement the appropriate workflow moving forward.

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