Washington County, FLLocal Government

Item 2024‐001 – Suspension and Debarment (Repeat) COVID-19 Coronavirus State and Local Fiscal Recovery – ALN 21.027 U.S. Department of Treasury Federal Award Year ‐ 2021 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Non‐Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a nonprocurement 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. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition – Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause – The County lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs – Not determinable. Effect – Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation – We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management’s Response – Management agrees with the finding. The County will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Deputy Clerk, Finance will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2025.

Item 2023‐001 – Suspension and Debarment (Repeat) COVID-19 Coronavirus State and Local Fiscal Recovery – ALN # 21.027 U.S. Department of Treasury Federal Award Year ‐ 2021 Criteria – 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” Non‐Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a nonprocurement 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. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition – Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause – The County lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs – Not determinable Effect – Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation – We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management’s Response – Management agrees with the finding. The County will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Deputy Clerk, Finance will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2024.

Item 2022-001 ? Suspension and Debarment Education Stabilization Fund: COVID-19 Coronavirus State and Local Fiscal Recovery ? ALN # 21.027 U.S. Department of Treasury Federal Award Year - 2021 Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement 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. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment. Cause ? The County lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a potential vendor has not been suspended or debarred could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment. Management?s Response ? Management agrees with the finding. The County will implement additional controls to ensure there is evidence of review of covered transactions over $25,000 for suspension and debarment prior to payment. Deputy Clerk, Finance will be responsible for the corrective action and anticipates completion of corrective action will be taken before September 30, 2023.

BCC 2021-003 ? SUBRECIPIENT MONITORING ? CONTROLS FEDERAL AGENCY: U.S. DEPARTMENT OF TREASURY PASS-THROUGH ENTITY: FLORIDA EXECUTIVE OFFICE OF GOVERNOR, DIVISION OF EMERGENCY MANAGEMENT PROGRAM: COVID-19: CORONAVIRUS RELIEF FUND, ALN 21.019 AWARD YEAR: 2020 FINDING TYPE: SIGNIFICANT DEFICIENCY QUESTIONED COST: NONE CRITERIA: Under 2 CFR 200.332(f), pass-through entities must verify that every subrecipient is audited as required by 2 CFR Part 200 Subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. CONDITION: The County did not verify that its subrecipient for this program had a single audit performed, and does not have a policy or control in place to review subrecipient audit reports. CAUSE: Lack of knowledge of the requirement due to the County not historically having subrecipients. EFFECT: Without policies and controls in place there is a possibility that the subrecipient did not have a single audit performed when one was required, or that the subrecipient had single audit findings for this program that the County should have followed up on. However, the subrecipient?s audit reports were reviewed during the audit and it was determined that the subrecipient did have a single audit performed as required, with no findings. RECOMMENDATION: We recommend the County establish a policy and controls for subrecipient monitoring in accordance with Uniform Guidance and other federal and/or state requirements, including reviewing subrecipient audit reports. VIEWS OF RESPONSIBLE OFFICIALS: See Management?s Response and Corrective Action Plan beginning page 104.

BCC 2021-005 ? REPORTING ? CONTROLS FEDERAL AGENCY: U.S. DEPARTMENT OF HOMELAND SECURITY, FEDERAL EMERGENCY MANAGEMENT AGENCY PASS-THROUGH ENTITY: FLORIDA EXECUTIVE OFFICE OF GOVERNOR, DIVISION OF EMERGENCY MANAGEMENT PROGRAM: COVID-19: DISASTER GRANTS-PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS), ALN 97.036 AWARD YEAR: DR 4486 - 2020 FINDING TYPE: SIGNIFICANT DEFICIENCY QUESTIONED COST: NONE CRITERIA: Per the County?s grant agreements with Florida Division of Emergency Management (FDEM), quarterly reports are required to be submitted through FloridaPA.com that include project costs and expenditures for each large project. Amounts in the quarterly reports should reconcile to the County?s accounting records and represent actual expenditures. CONDITION: For the large project under COVID-19 disaster 4486 tested for compliance with this requirement (the only project under this grant), including all quarterly reports submitted during the 2021 fiscal year, the reported expenditures were unable to be reconciled to actual quarterly expenditures per the invoices and other supporting documentation in the County?s files. CAUSE: Estimated expenditures for this large project in the quarterly reports as the County was still working on identifying all expenditures to be claimed for this project, and through date of the audit this identification of expenditures is still in process. EFFECT: Incorrect project expenditures were reported to FDEM in quarterly reports, which can affect project cost tracking. Under the terms of the grant agreement, submission of inaccurate or incomplete reports could result in FDEM ceasing disbursements to the County, termination of the agreements, or other remedies. However, it is believed this only affects this single large project as it was an expedited project which was paid up front, rather than a cost-reimbursement project. RECOMMENDATION: We recommend staff handling quarterly reports ensure that only actual expenditures are reported for all projects, and a specific review of quarterly report information by a higher level prior to submission to ensure accurate reporting of project costs. VIEWS OF RESPONSIBLE OFFICIALS: See Management?s Response and Corrective Action Plan beginning page 104.