Brown CountyLocal Government

CONTROLS OVER ELIGIBILITY (2024-003) Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2405MN5ADM and 2405MN5MAP, 2024 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2405MN5ADM and 2405MN5MAP Award Period: Year-Ended December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Standard internal control procedures suggest that casefile eligibility determination should have a timely review documented by someone other than the preparer. Condition: During testing of controls over eligibility, it was noted the County did not have adequate internal controls designed to ensure that casefiles were reviewed for correct eligibility determination. Questioned Costs: None. Context: During testing of controls over eligibility casefile reviews, it was noted that there were no reviews for Non-MAGI cases and MAGI cases. Cause: Lack of management oversight. Effect: Errors made in determining eligibility may not be discovered and benefits may be issued to clients who are not eligible. Repeat Finding: Yes, 2023-005 Recommendation: We recommend the County increase review over casefiles and ensure that there are performed on a periodic basis throughout the year. Views of Responsible Officials: There is no disagreement with the audit finding.

RANDOM MOMENT STUDY EMPLOYEE LISTING (2024-004) Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2405MN5ADM and 2405MN5MAP, 2024 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2405MN5ADM and 2405MN5MAP Award Period: Year-Ended December 31, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Compliance standards require the County to separate individuals listed on the RMS listing into separate account coding for use on the quarterly reports. Condition: During testing of reporting requirements, it was noted that the County did not have adequate internal controls designed to ensure that the individuals coded to the RMS general ledger accounts were also included on the RMS quarterly listing. Questioned Costs: None. Context: During testing of the Social Service Random Moment Study listing, two of two quarterly reports tested had an individual that was coded to the RMS listing account codes and should not have been. Cause: Lack of management oversight. Effect: There is minimal effect on the programs. Due to the funding structure, the random moment studies are only used to determine the allocation percentages to the various federal programs and not to determine the total amount of reimbursements. Repeat Finding: No Recommendation: We recommend the County review the RMS listings and employees within the department and account codes to ensure the proper employees are included on the listing and general ledger accounts. Views of Responsible Officials: There is no disagreement with the audit finding

CONTROLS OVER REPORTING – C&TC ANNUAL REPORT (2024-005) Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2405MN5ADM and 2405MN5MAP, 2024 Pass-Through Agency: Brown-Nicollet Community Health Services Pass-Through Numbers: 2405MN5ADM and 2405MN5MAP Award Period: Year-Ended December 31, 2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or Specific Requirement: Standard internal control procedures suggest that reports should have a timely review documented by someone other than the preparer. Condition: During testing of reporting requirements, it was noted that the County did not have adequate internal controls designed to ensure that the annual Child and Teen Check-Up (C&TC) report was reviewed prior to submission. Questioned Costs: None. Context: During testing of the annual C&TC report, it was noted that the report was not reviewed by someone other than the preparer. Cause: Lack of management oversight. Effect: The amounts reported could be inaccurate and there is increased risk that the County would not correct it internally. Repeat Finding: No Recommendation: We recommend the County have a secondary person review these reports before they are submitted to DHS. 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: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM and 2305MN5MAP, 2023 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2305MN5ADM and 2305MN5MAP Award Period: Year-Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Standard internal control procedures suggest that reports should have a timely review documented by someone other than the preparer. Condition: During testing of reporting requirements, it was noted the County did not have adequate internal controls designed to ensure that the annual report was reviewed prior to submission. Questioned Costs: None. Context: During testing of the annual Collaborative LCTS report, it was noted that the report was not reviewed by someone other than the preparer. Cause: Lack of management oversight. Effect: The amounts reported could be inaccurate and there is increased risk the county would not find it internally. Repeat Finding: 2022-003 Recommendation: We recommend the County implement procedures to have a secondary person review the reports before they are submitted to the Minnesota Department of Human Services. 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: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM and 2305MN5MAP, 2023 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2305MN5ADM and 2305MN5MAP Award Period: Year-Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Standard internal control and compliance procedures require that funds be disbursed to the collaborative in a timely fashion, no later than 30 days after receipt. Condition: During testing of special provisions, it was noted that the County did not disburse two quarters of funding to the collaborative within 30 days of receipt. Questioned Costs: None. Context: During testing of special provisions, it was noted that the County did not disburse the 1st and 2nd quarter LCTS receipts to the collaborative within 30 days. Cause: Lack of management oversight and staff turnover. Effect: The Collaborative could not have enough fund to continue operations. Repeat Finding: 2022-004 Recommendation: We recommend the County ensure that someone is disbursing the money received to the collaborative in a timely fashion. 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: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2305MN5ADM and 2305MN5MAP, 2023 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2305MN5ADM and 2305MN5MAP Award Period: Year-Ended December 31, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Standard internal control procedures suggest that casefile eligibility determination should have a timely review documented by someone other than the preparer. Condition: During testing of controls over eligibility, it was noted the County did not have adequate internal controls designed to ensure that casefiles were reviewed for correct eligibility determination. Questioned Costs: None. Context: During testing of controls over eligibility casefile reviews, it was noted that only seven Non-MAGI cases and six MAGI cases were completed for each program. This is not a sufficient control. Cause: Lack of management oversight. Effect: Errors made in determining eligibility may not be discovered and benefits may be issued to clients who are not eligible. Repeat Finding: No Recommendation: We recommend the County increase review over casefiles and ensure that there are performed on a periodic basis throughout the year. Views of responsible officials: There is no disagreement with the audit finding.

CONTROLS OVER REPORTING (2022-003) Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2205MN5ADM and 2205MN5MAP, 2022 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2205MN5ADM and 2205MN5MAP Award Period: Year-Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Standard internal control procedures suggest that reports should have a timely review documented by someone other than the preparer. Condition: During testing of reporting requirements, it was noted the County did not have adequate internal controls designed to ensure quarterly reports were reviewed prior to submission. Questioned Costs: None. Context: During testing of the LCTS public health reports, it was noted that two of two quarterly reports were not reviewed by someone other than the preparer. During testing of the LCTS probation reports, it was noted that two of two quarterly reports were not reviewed by someone other than the preparer. During testing of the 2556 social services fund reports, it was noted that two of two quarterly reports were not reviewed by someone other than the preparer in a timely manner. Cause: The Minnesota Department of Human Services does not require a reviewer, but it is a good procedure to have in place. Effect: The amounts reported could be inaccurate and there is increased risk the county would not find it internally. Repeat Finding: Not applicable. Recommendation: We recommend the County implement procedures to have a secondary person review the reports before they are submitted to the Minnesota Department of Human Services. Views of responsible officials: There is no disagreement with the audit finding.

CONTROLS OVER SPECIAL PROVISIONS (2022-004) Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Medical Assistance Program (Medicaid Cluster) Assistance Listing Number: 93.778 Federal Award Identification Number and Year: 2205MN5ADM and 2205MN5MAP, 2022 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 2205MN5ADM and 2205MN5MAP Award Period: Year-Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Standard internal control and compliance procedures require that funds be disbursed to the collaborative in a timely fashion, no later than 30 days after receipt. Condition: During testing of special provisions, it was noted that the County did not disburse two quarters of funding to the collaborative within 30 days of receipt. Questioned Costs: None. Context: During testing of special provisions, it was noted that the County did not disburse the 3rd and 4th quarter LCTS receipts to the collaborative until June 2023. Cause: Lack of management oversight and staff turnover. Effect: The Collaborative could not have enough fund to continue operations. Repeat Finding: Not applicable. Recommendation: We recommend the County ensure that someone is disbursing the money received to the collaborative in a timely fashion. Views of responsible officials: There is no disagreement with the audit finding.

SUSPENSION AND DEBARMENT (2022-005) Federal Agency: U.S. Department of Transportation Federal Program Name: Highway Planning and Construction (Highway Planning and Construction Cluster) Assistance Listing Number: 20.205 Federal Award Identification Number and Year: 2022-M1, 2022 Pass-Through Agency: Minnesota Department of Transportation Pass-Through Number: 2022-M1 Award Period: Year-Ended December 31, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Standard internal control and compliance procedures suggest that the County should ensure the suspension and debarment language is in the signed contract or if not in the contract, the county retains documentation of the County's search on sam.gov. In addition, according to Uniform Guidance 2 CFR 180.300, the County must check for federally suspended or debarred vendors prior to entering a covered transaction. Condition: The County did not ensure that a contractor was not suspended or debarred, and language was not within the contract. Questioned Costs: None. Context: The County entered into a contract for the purchase of seal coat oil, and the contract did not include suspension and debarment self-certification language. The County also did not perform its own search on the sam.gov website. Cause: Management oversight due to familiarity with the contractor. Effect: Federal funds could have been paid to a suspended or debarred contractor. Repeat Finding: Not applicable. Recommendation: We recommend that the County follow its established internal control procedures regardless of familiarity with contractors. Views of responsible officials: There is no disagreement with the audit finding.

CONTROLS OVER REPORTING (2020-003) Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Medical Assistance Program (Medicaid Cluster) CFDA Number: 93.778 Pass-Through Agency: Minnesota Department of Human Services and Brown-Nicollet Community Health Services Pass-Through Numbers: 2005MN5ADM and 2005MN5MAP Compliance Requirement Affected: Reporting Award Period: Year-Ended December 31, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Standard internal control procedures suggested that reports should have a review documented by someone other than the preparer. The quarterly reports are also required to be submitted 20 days after the quarter end. Condition and Context: The monthly CTC reports filed were not reviewed by someone other than the preparer. It was noted that three of the twelve monthly CTC reports were not reviewed by someone other than the preparer. During testing of the LCTS public health reports, it was noted that one quarter was not submitted timely. The sample sizes were based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Questioned Costs: None. Cause: Oversight by management. Possible Effect: The amounts reported on the reports could be incorrect and there is an increased chance that the county would not catch the error internally. Also, the reports could have been denied and funds not received due to late submission. Repeat Finding: Not applicable. Recommendation: We recommend the County has a secondary person reviewing these reports before they are submitted to DHS and also ensure to submit all required reports by the specified deadline. View of Responsible Officials: There is no disagreement with the audit finding.

CONTROLS OVER REPORTING (2020-004) Federal Agency: U.S. Department of Treasury Federal Program Title: COVID-19 Coronavirus Relief Fund CFDA Number: 21.019 Pass-Through Agency: Brown-Nicollet Community Health Services Pass-Through Numbers: SLT0232 Compliance Requirement Affected: Reporting Award Period: Year-Ended December 31, 2020 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria: Standard internal control procedures suggested that reports should be submitted in a timely manner and comply with the deadlines in the grant agreement. Condition and Context: It was noted that one out of four reports submitted for the September through December CICT portion of the COVID-19 Coronavirus Relief Fund grant were not submitted timely. The highest priority of Public Health Department during the COVID-19 state of emergency pandemic was to care for and treat those affected. This specific grant agreement was signed in mid-December 2020. The related financial reports were submitted in an expediated manner, with communication maintained with governing authorities to ensure that the required forms were obtained and completed. The sample sizes were based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits. Questioned Costs: None. Cause: Oversight by management due to it being a new grant. Possible Effect: The reports could have been denied and funds not received due to late submission. Repeat Finding: Not applicable. Recommendation: We recommend the County implement procedures to ensure any future reports are submitted on or before the due date. View of Responsible Officials: There is no disagreement with the audit finding.

Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Medical Assistance Program (Medicaid Cluster) CFDA Number: 93.778 Pass-Through Agency: Minnesota Department of Human Services Pass-Through Numbers: 1905MN5ADM Compliance Requirement Affected: Eligibility Award Period: Year-Ended December 31, 2019 Type of Finding: Significant Deficiency in Internal Control over Compliance and Compliance Criteria: According to Uniform Guidance 2 CFR Part 200, Appendix XI Compliance Supplement for CFDA 93.778 and 42 CFR section 431.10, the federal eligibility compliance requirements for Medical Assistance include verification of assets and social security numbers of applicants. In order for benefit amounts to be calculated correctly, it?s necessary for the asset information and social security number to be retained and entered into the state eligibility system, MAXIS, accurately. Condition and Context: During our testing of Medical Assistance, it was noted that one of the sixty case files did not have documentation to support the assets that were entered into the state system, MAXIS. Additionally, during our testing of Medical Assistance, it was noted that one of the sixty case files did not have documentation to support the social security number that was entered into the state system, MAXIS. Our sample size was based on guidance from chapter 11 of the AICPA Audit Guide, Government Auditing Standards and Single Audits and was a statistically valid sample. Questioned Costs: Not applicable. The County administers the program, but benefits to participants in this program are paid by the State of Minnesota. Cause: Lack of oversight by management. Possible Effect: The improper input of the social security number or updating of asset information in MAXIS and the lack of verification or follow-up of eligibility determining factors increases the risk that a program participant will receive benefits when they are not eligible. Repeat Finding: Yes - Finding 2017-001 Recommendation: We recommend the County implement procedures to provide reasonable assurance that all necessary documentation to support eligibility determinations is retained and is properly input or updated in MAXIS and issues followed up on in a timely manner. View of Responsible Officials: There is no disagreement with the audit finding.

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