County of Dodge

Finding 2021-002 Program ALN: 93.498 Program Title: COVID-19 Provider Relief Fund Pass-through Agency: Wisconsin Department of Health Services (DHS) Award Year: 2020-2021 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the federal award to ensure compliance with federal statutes, regulations and the terms and conditions of the federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services (HHS). Condition/Context: For both the Health and Human Services and Clearview divisions, 2 of the 4 reports tested were either not properly reviewed, or the review was determined not to be effective as errors existed in the reports. In addition, during investigation and examining of the expense detail provided, it was discovered that "Other Healthcare Expenses", which made up a significant portion of total expenses reported, were ineligible costs and did not pertain to PRF. These samples were not statistically valid. Cause: The County did not have internal control processes and procedures in place requiring an independent person to review the reports before submission to ensure the revenue loss calculation and amounts reported were accurate. As PRF was a new program in 2021, there was also a lack of knowledge regarding what costs were allowed. Effect: Information within the period reports submitted could and do contain errors. Questioned Costs: Costs in the amount of $347,591 were reported under ALN 93.498 that either did not have supporting documentation or did not relate to allowable costs for the program. Recommendation: The County should review its internal control procedures to ensure there are proper review and approval processes over completeness and accuracy of reports are in place before submissions to federal agencies. The County should also review what costs are allowable under the PRF's federal requirements. Corrective Action Plan Dodge County Finance Department will update its internal control review procedure for all Federal and State grants which will include: 1 Identification of who would be considered a qualified reviewer. This will be determined by financial staff in respective areas and will be based on the reviewer?s knowledge of grants and qualifying eligible costs as they relate to the particular grant. 2 A detailed review process for cost eligibility. This procedure will identify the step by step process to determine cost eligibility and required documentation need to support the eligible costs. The procedure will also identify the process for submitting reimbursement request to federal and state agencies. 3 Verification of eligible costs reported for reimbursement and ensure actual expense dates and submission for reimbursement are within grants timeline. Dodge County will review the conditions of the Provider Relief Fund?s federal grant and ensure expenses are allowable. 4 Verification that the person(s) preparing the report for submission is different from the person reviewing reimbursement requests and eligibility of costs. 5 All review steps will signed off and dated by the person performing the step. The Finance Department will be reviewing documentation for Federal and State grant revenue to ensure compliance with the review process. Name(s) of Contact Person(s) Responsible for Corrective Action: Eileen Lifke, Interim Finance Director, Angela Petruske, Health & Human Services Division Manager Fiscal, Nicole Grossman, Clearview Director of Finances. Anticipated Completion Date: Finance will have a policy ready for Finance Committee approval at the March 2023 Finance Committee meeting. In the meantime, Finance will be monitoring grant submission for all areas except Health & Human Services since they have a process in place. Health & Human Services will implement this effective immediately.

Finding 2020-002 Program CFDA Number: 21.019 Program Title: COVID-19 Coronavirus Relief Fund Pass-through Agency: Wisconsin Department of Health Services (DHS) Award Year: 2020 Criteria: According to the program grant agreement, the County is required to submit monthly expenditure reports for reimbursement through CARS. In addition, 2 CFR 200.303 Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition/Context: A sample of 1 of the 6 monthly (July through December) CARS reports was selected. There was no evidence retained to support the review of the reports before they were submitted. Our sample was not statistically valid. Cause: The County?s current processes do not require the retention of documentation of the review and approval of the CARS report by someone other than the preparer. Effect: CARS reports submitted could be inaccurate. Questioned Costs: None noted. Recommendation: The County should consider enhancing its internal control documentation related to the review of CARS reporting. Corrective Action Planned: Each CARS report is created by the division manager and reviewed by the accounting technician before it is submitted to the State. We have created a verification of review spreadsheet that includes the date and name of who reviewed, submitted, and reconciled. Name(s) of Contact Person(s) Responsible for Corrective Action: Angela Petruske, HSHD Fiscal Division Manager Anticipated Completion Date: September 1, 2021

Finding 2020-003 Program CFDA Number: 93.658 Program Title: Foster Care ? Title IV-E Pass-through Agency: Wisconsin Department of Children and Families (DCF) Award Year: 2020 Criteria: According to the program grant agreement, the County is required to submit monthly expenditure reports for reimbursement through SPARC. In addition, 2 CFR 200.303 Internal Controls requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition/Context: A sample of 3 of the 12 monthly SPARC reports was selected. There was no evidence retained to support the review of the reports before they were submitted. Our sample was not statistically valid. Cause: The County?s current processes do not require the retention of documentation of the review and approval of the SPARC report by someone other than the preparer. Effect: SPARC reports could be inaccurate. Questioned Costs: None noted. Recommendation: The County should consider enhancing its internal control documentation related to the review of SPARC reporting. Corrective Action Planned: Each SPARC report is created by the division manager and reviewed by the accounting technician before it is submitted to the State. We have created a verification of review spreadsheet that includes the date and name of who reviewed, submitted, and reconciled. Name(s) of Contact Person(s) Responsible for Corrective Action: Angela Petruske, HSHD Fiscal Division Manager Anticipated Completion Date: September 1, 2021

GSA_MIGRATION

2015-002