Taylor County

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Medical Assistance Program Federal Assistance Listing Number: 93.778 Pass-Through Agency: WI DHS Pass-Through Numbers: N/A Award Period: January 1, 2024 – December 31, 2024 Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Compliance Requirement Allowable Costs Criteria The County’s Human Services Department must authorize services for children enrolled in the Children’s Long-Term Support (CLTS) Program. When services are provided by third-party vendors, those vendors submit their costs to the Third-Party Administrator (TPA), which processes reimbursements directly through the CLTS Program. Condition The County authorized a vendor to provide services to a child enrolled in the CLTS program through December 31, 2024. However, after the child relocated out of the County, the County had updated the child’s Individual Service Plan for the service to end effective September 30, 2024. The provider continued to submit claims and received reimbursement through the CLTS Third Party Administration system for services rendered in October, November, and December. Questioned Costs The provider received reimbursement at $75.30 per month for three months for a total of $225.90. Context Of the nine expenditures tested one was not allowable. Cause The County did not have a procedure in place to review the monthly services billed by third party vendors to the CLTS Third Party Administration to ensure that only allowable activities were being reported. Effect A provider billed and received payment for services that were not eligible for reimbursement. Repeat Finding No Recommendation We recommend that the County implement a procedure by which a monthly review of the activities billed by providers to the CLTS Third Party Administration is performed with special attention on any authorized changes in services that occurred during the month. Views of Responsible Officials There is no disagreement with this finding

Federal Agency: U.S. Department of Treasury Federal Program Title: State and Local Fiscal Recovery Funds Federal CFDA: 21.027 Pass-Through Agency: Direct Program Pass-Through Numbers: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Material weakness in Internal Control Over Compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal 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 non-procurement 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. Condition: The County entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The County did not perform a search for the one procurement transaction that exceeded the covered transaction threshold. Cause: The County departments were not aware of the requirements and did not have a procedure in place to perform a search for suspension and department associated for covered transactions. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: Repeat of Finding 2022-003 Recommendation: We recommend that the County review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: Refer to the management response per the corrective action plan.

Federal Agency: U.S. Department of Treasury Federal Program Title: State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Pass-Through Agency: Direct Program Pass-Through Numbers: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Material weakness in Internal Control Over Compliance, Other Matters Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal 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 non-procurement 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. Condition: The County entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The County did not perform a search for the one procurement transaction that exceeded the covered transaction threshold. Cause: The County departments were not aware of the requirements and did not have a procedure in place to perform a search for suspension and department associated for covered transactions. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: Repeat of Finding 2022-003 Recommendation: We recommend that the County review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: Refer to the management response per the corrective action plan.

Federal Agency: U.S. Department of Treasury Federal Program Title: State and Local Fiscal Recovery Funds Federal CFDA: 21.027 Pass-Through Agency: Direct Program Pass-Through Numbers: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Material weakness in Internal Control Over Compliance Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal 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 non-procurement 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. Condition: The County entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The County did not perform a search for the one procurement transaction that exceeded the covered transaction threshold. Cause: The County departments were not aware of the requirements and did not have a procedure in place to perform a search for suspension and department associated for covered transactions. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend that the County review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Treasury Federal Program Title: State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Pass-Through Agency: Direct Program Pass-Through Numbers: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Compliance Requirement: Procurement, Suspension & Debarment Criteria: Non-federal 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 non-procurement 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. Condition: The County entered into a procurement transaction that exceeded the covered threshold and did not perform a search for suspension and debarment in accordance with 2 CFR section 180.220. Questioned Costs: None Context: The County did not perform a search for the two procurement transactions that exceeded the covered transaction threshold. Cause: The County departments were not aware of the requirements and did not have a procedure in place to perform a search for suspension and department associated for covered transactions. Effect: Certain vendors could be used that are considered suspended or debarred by the federal government resulting in noncompliance. Repeat Finding: No Recommendation: We recommend that the County review its policies over suspension and debarment review to ensure they are maintaining compliance and controls over verifying or contracting with vendors that are allowable. Views of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Pass-Through Agency: Direct Program Pass-Through Numbers: N/A Award Period: March 3, 2021 – December 31, 2026 Type of Finding: Material Weakness in Internal Control Over Compliance, Other Matters Compliance Requirement: Reporting Criteria or Specific Requirement: Counties who have received less then $10 million in State and Local Fiscal Recovery Funds are required to submit an annual Project and Expenditure Report by April 30 of each year. This report is required to include any projects in which there were obligations or expenditures for any project that is to be funded by the Coronavirus State and Local Fiscal Recovery Funds during the preceding April 1 through March 31 period. Condition: The Project and Expenditure Report that was submitted April 24, 2023, did not include expenditures totaling $1,395,654 that had occurred during the timeframe of the report. Questioned Costs: None Context: The County reported total expenditures incurred of $552,327 when actual expenditures through the period of the report were $1,947,981. Cause: The County had identified a project that was to be funded by the State and Local Fiscal Recovery Funds program, however the County had recorded the expenditures outside of the ARPA fund created by the County to track expenditures related to the program. As the costs were not identified within the fund, the County did not report them as federal expenditures until the County recorded a transfer to reimburse the fund where the expenditures were recorded instead of when the expenditures were initially incurred. This transfer occurred after the April 24, 2023, report was filed. Effect: The Project and Expenditure Report was incorrect. Repeat Finding: No Recommendation: We recommend that the County review its procedures for tracking of federal expenditures related to the State and Local Fiscal Recovery Funds and ensure that all expenditures are recorded within the fund at the time they are incurred. Views of Responsible Officials: Refer to the management response per the corrective action plan.

2020-002 Uniform Guidance and State Single Audit Guidelines Findings Financial Reporting for Federal and State Awards Repeat Finding: 2019-002 Federal CFDA: All Compliance Requirement: Other Condition: Uniform Guidance and the State Single Audit Guidelines require the County to prepare appropriate financial statements, including the schedules of expenditures of federal and state awards. While the current staff of the County maintains financial records supporting amounts reported in the schedules of expenditures of federal and state awards, the County contracts with CLA to compile the data from these records and assist in the preparation of the single audit report for the County. Criteria: Having staff with expertise in federal and state financial reporting prepare the County?s single audit report is an internal control intended to prevent, detect, and correct a potential misstatement in the schedules of expenditures of federal and state awards, or accompanying notes to the schedule. Context: While performing audit procedures, it was noted that management does not have internal controls in place to provide reasonable assurance that the schedules of expenditures of federal and state awards are prepared in accordance with Uniform Guidance and the State Single Audit Guidelines. Cause: The additional costs associated with hiring staff sufficiently experienced to prepare the County?s single audit report, including the additional training time, outweigh the derived benefits Effect: The County could receive federal or state grant awards which are not included in the accompanying Schedules of Expenditures of Federal and State Awards. Recommendation: We recommend County personnel continue reviewing the County?s single audit report. While it may not be cost beneficial to hire additional staff to prepare these items, a thorough review of this information by appropriate staff of the County is necessary to ensure all federal and state financial assistance programs are properly reported in the County?s single audit report. View of Responsible Officials: There is no disagreement with the audit finding.

2020-003 Uniform Guidance and State Single Audit Guidelines Findings Significant Deficiency in Internal Control Over Compliance Federal CFDA: 21.019 COVID-19 ? Coronavirus Relief Fund Reporting U.S. Department of the Treasury ? Wisconsin Department of Administration Compliance Requirement: Reporting Criteria: 2 CFR 200.302 requires that ?The financial management system of each non-Federal entity must provide the following: (1) Identification, in its accounts, of all Federal Awards received and expended and all the Federal programs under which they were received. Federal program and Feder award identification must include, as applicable, the CFDA title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any.? Grant claims filed by the County to various granting agencies must be accurate, reconcile to the County general ledger system, and for cost-reimbursement grants, represent costs incurred. Internal controls should be designed and implemented to prevent and detect errors in the data reported on the grant claims. Segregation of duties is an internal control intended to prevent or decrease the occurrence or errors or intentional fraud. Segregation of duties ensures that no single employee has control over all phases of the transaction. Context: While performing audit procedures, it was noted that there was no review other than the prepared of expenditures submitted and claimed for the Routes to Recovery and CARS portion of the Coronavirus Relief Funds. Condition: There was no review of the Routes to Recovery reports and claims for reimbursement by someone other than the preparer. Cause: The County has begun but not finalized an assessment of its financial management system and related internal controls over federal awards, along with an evaluation of existing policies for compliance with Uniform Guidance by year-end. Effect: The County could become noncompliant with the requirement of Uniform Guidance, resulting in future findings and questioned costs related to federal awards administered by the County. Recommendation: We recommend County continue the process in assessing its financial management systems and related internal controls over federal awards during the 2020 fiscal year. This assessment should include evaluating existing policies and procedures to determine where additional enhancements should be made or new policies created, a plan to communicate these policies to County employees and procedures to periodically revie and update, as considered necessary View of Responsible Officials: There is no disagreement with the audit finding.

2020-004 Uniform Guidance and State Single Audit Guidelines Findings Significant Deficiency in Internal Control Over Compliance Federal CFDA: 20.219 COVID-19 ? Recreational Trails Programs U.S. Department of the Transportation ? Wisconsin Department of Natural Resources Compliance Requirement: Procurement Criteria: 2 CFR 200.214 requires that non-federal entities to follow suspension and debarment regulations outlined in 2 CFR part 180. When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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. Context: The County did not review either of the vendors that were subject to review to ensure they were not suspended or debarred when initiating covered transactions in the current year. Condition: There was no search performed for suspension or debarment. Cause: The department in charge of administering the grant was not aware of the requirements under suspension and debarment. Effect: The County could contract with a vendor that has been suspended or debarred from receiving federal funds. Recommendation: We recommend County use sam.gov or the ELPS listing to review clients at the beginning of the year or before a transaction is incurred in accordance with Uniform Guidance requirements. View of Responsible Officials: There is no disagreement with the audit finding.

2019-002 Financial Reporting for Federal and State Awards Repeat of Finding 2018-002 Condition: Uniform Guidance and the State Single Audit Guidelines require the County to prepare appropriate financial statements, including the schedules of expenditures of federal and state awards. While the current staff of the County maintains financial records supporting amounts reported in the schedules of expenditures of federal and state awards, the County contracts with CLA to compile the data from these records and assist in the preparation of the single audit report for the County. Context: While performing audit procedures, it was noted that management does not have internal controls in place to provide reasonable assurance that the schedules of expenditures of federal and state awards are prepared in accordance with Uniform Guidance and the State Single Audit Guidelines. Criteria: Having staff with expertise in federal and state financial reporting prepare the County?s single audit report is an internal control intended to prevent, detect and correct potential misstatement in the schedules of expenditures of federal and state awards or accompanying notes to the schedule. Cause: The additional costs associated with hiring staff sufficiently experienced to prepare the County?s single audit report, including the additional training time, outweigh the derived benefits. Effect: The County could receive federal or state grant awards which are not included in the accompanying Schedules of Expenditures of Federal and State Awards. Recommendation: We recommend County personnel continue reviewing the County?s single audit report. While it may not be cost beneficial to hire additional staff to prepare these items, a thorough review of this information by appropriate staff of the County is necessary to ensure all federal and state financial assistance programs are properly reported in the County?s single audit report. View of Responsible Officials: There is no disagreement with the audit finding.

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