Cobb County, GeorgiaLocal Government

Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subrecipient administered the subaward in compliance with the terms and conditions of the subaward. Specifically, the County had not verified that a subrecipient that was expected to be audited as required by 2 CFR Part 200, Subpart F, met this requirement (2 CFR section 200.331(f)). Cause/Effect: The County did not have adequate procedures in place for monitoring that a subrecipient had complied with federal regulations. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients. Views of Responsible Officials and Planned Corrective Actions: The County will review the monitoring plan related to the program and ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

Questioned Cost: $28,554 - Procurement. Questioned Cost: $139,825 - Suspension and Debarment. Criteria: The County must use its own documented procurement procedures, which should reflect applicable state and local laws and regulations and must conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The County did not comply with applicable federal statutes for procurement for one contract funded by the program. The County did not retain documentation that the procurement complied with the requirements of federal regulations relating to suspension and debarment for two contracts funded by the program. Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and will continue to work with the Purchasing Department to ensure acceptable documentation has been retained. We will also discuss additional review procedures with the responsible departments for all contract awards with federal funding. Effect: The County did not comply with federal regulations relating to procurement and suspension and debarment. Repeat Finding: Repeat Finding of 2022-004. Auditor's Recommendation: The County should review requirements relating to contract awards where federal funding will be used and implement procedures to retain required documentation to support the County has complied with federal guidelines.

Questioned Cost: $30,520. Criteria: The regulation in 2 CFR 200.77 sets forth that the Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award. The Period of Performance represents the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. Condition: Funding totaling $30,520 was paid to a subrecipient for costs incurred prior to the grant’s period of performance start date. Cause: The County had a contract with the subrecipient that spans several periods. Views of Responsible Officials and Planned Corrective Actions: The County agrees with this finding and will implement revised policies and procedures to ensure all pre-award payments will be dated during the 2-year award period. Effect: The request for reimbursement to the Federal agency by the County included costs prior to the grant’s period of performance start date. Repeat Finding: Repeat finding of 2022-002. Auditor's Recommendation: The County should review procedures for tracking grant timelines to ensure funding requests from the federal agency and reimbursements to subrecipients relate to costs within the dates set forth in the grant agreements executed with the Federal entity.

Criteria: The regulation in 2 CFR 200.77 sets forth that the Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award. The Period of Performance represents the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. Condition: Funding totaling $300,000 was paid to a subrecipient for costs incurred prior to the grant?s period of performance start date. Cause: The County had a contract with the subrecipient that spans several periods. Effect: The request for reimbursement to the Federal agency by the County included costs prior to the grant?s period of performance start date. Identification as a Repeat Finding: A similar finding was reported in the prior year?s audit as finding number 2021-002. Auditor's Recommendation: The County should review procedures for tracking grant timelines to ensure funding requests from the federal agency and reimbursements to subrecipients relate to costs within the dates set forth in the grant agreements.

Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.

Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition/Effect: For several contracts charged to these grants, the County did not have documentation verifying that the vendors were not suspended or debarred. Auditor's Recommendation: The County should review requirements relating to contract awards where federal funding will be used and implement procedures to retain acceptable documentation of verification that the contractor has not been suspended or debarred. Views of Responsible Officials and Planned Corrective Actions: The County agrees with the recommendation and will work with the Purchasing Department to ensure acceptable verification has been addressed. We will also discuss additional review procedures with the responsible departments for all contract awards with federal funding.

Criteria: Agency financial reporting requirements are designed to ensure maximum transparency around the use of ERA award funds consistent with 2 CFR 200 and to enable sufficient monitoring by the Treasury. Condition: Costs reported on the 3/31/2022 ERA1 quarterly report submission did not include the cumulative total expended which is a key line item. Cause/Effect: The report did not include key line item information required. Auditor's Recommendation: The County should develop procedures to ensure that reporting submissions include all required data.

Criteria: The regulation in 2 CFR 200.77 sets forth that the Federal awarding agency or pass-through entity must include start and end dates of the period of performance in the Federal award. The Period of Performance represents the time during which the non-Federal entity may incur new obligations to carry out the work authorized under the Federal award. Condition: Funding totaling $500,000 was paid to a subrecipient for costs incurred prior to the grant?s period of performance start date. Cause: The County had a contract with the subrecipient that spans several periods. Effect: The request for reimbursement to the Federal agency by the County included costs prior to the grant?s period of performance start date. Auditor's Recommendation: The County should review procedures for tracking grant timelines to ensure funding requests from the federal agency and reimbursements to subrecipients relate to costs within the dates set forth in the grant agreements.

Criteria: Agency financial reporting requirements are designed to ensure maximum transparency around the use of ERA award funds consistent with 2 CFR 200 and to enable sufficient monitoring by the Treasury. Expenditures and obligations reported in quarterly reports by the grantee are inputs to Treasury?s ERA 2 reallocation expenditure and obligation ratios. The reallocation expenditure ratio determines whether the grantee is subject to involuntary reallocation due to an insufficient ratio and the amount of excess funds subject to recapture by Treasury. Condition: Costs reported on the 9/30/2021 quarterly report submission was $1,204,892 lower than the costs reflected in the general ledger for the period. Cause: The County did not have adequate procedures for reconciling amounts reported to the supporting data. Effect: Amounts expended were understated in the report submitted to the Treasury for the period. Auditor's Recommendation: The County should develop procedures to ensure that amounts reported reconcile to the general ledger.

Criteria: The County has a Policy on Procurement and Contract Management that sets forth Procurement Procedures by which the County secures commodities, goods and services. Condition/Effect: The County did not follow the approval guidelines set forth in the Policy on Procurement and Contract Management relating to a contract made available from other governmental agencies. Auditor's Recommendation: The County should review internal control procedures relating to the review and approval of these type of contracts in relation to the County?s policy.

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