Elbert CountyLocal Government

Eligibility & Special Tests Material Weakness, Internal Control Over Compliance And Compliance ALN 93.658: Foster Care – Title IV-E Federal Agency: U.S. Department Of Health and Human Services Pass-Through Entity: Colorado Department of Human Services Criteria Or Specific Requirement: Per 45 CFR 1355.43(a) Title IV-E agencies are required to submit case file information with 45 days. Per 45 CFR 1355.20(a) permanency hearings and home visits must be held not less frequently than every 12 month during the continuation of foster care. These requirements are documented through the SS-9 and SS-10 forms by the County’s caseworkers. Additionally, Payment Rate Setting and Application requirements have been set by the Federal Agency, which require appropriate calculation of maintenance payments. Condition/Context: In our audit, we noted the County did not complete appropriate documentation for eight cases in a timely manner and one case of the eight tested that did not have the appropriate calculation of maintenance payments. Cause: The County did not have sufficient internal controls in place to ensure that required documentation was completed by the deadline and that appropriate payment amounts were made. Effect: Without adequate controls over eligibility determinations, the County did not complete required documentation by the required deadlines and had improper maintenance payments made of $2,593. Questioned Costs: $2,593. Identification As A Repeat Finding: N/A Recommendation: We recommend the County improve its internal controls by ensuring the personnel responsible are appropriately trained and monitored on federal grant requirements. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Eligibility Significant Deficiency, Internal Control Over Compliance ALN 93.778: Medicaid Cluster Federal Agency: U.S. Department Of Health and Human Services Pass-Through Entity: Colorado Department of Health Care Policy and Financing Criteria Or Specific Requirement: The Medicaid program provides medical assistance to individuals whose incomes and resources are insufficient to meet the costs of necessary medical services. Beneficiary eligibility is generally based on financial and non-financial criteria. The County is responsible for determining eligibility and establishing controls over the determination of eligible individuals. Condition/Context: Internal controls over the eligibility determinations are the responsibility of management. The County has a formal policy for reviews of eligibility determinations; however, this process was not functioning at the frequency that was set by the policy during 2023. Cause: The related review of eligibility determinations were completed at a lesser frequency than the formal policy stated; however, no ineligible recipients were noted. Effect: Without sufficient documentation and monitoring controls, the County may not timely detect an error in eligibility determinations. Questioned Costs: N/A Identification As A Repeat Finding: N/A Recommendation: We recommend that the County follow their documented internal control process or adjust process for over review of eligibility determinations. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Finding 2022-001 Reporting Material Weakness, Internal Control Over Compliance And Compliance ALN 21.027: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department Of Treasury Pass-Through Entity: N/A Criteria Or Specific Requirement: The Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) provide direct payments to states, U.S. territories, tribal governments, metropolitan cities, counties and nonentitlement units of local government may be utilized to provide government services, to the extent COVID-19 caused a reduction in revenues collected in the most recent full fiscal year, incurred between March 3, 2021 and December 31, 2024. Entities are required to provide reports to agencies to assist the agency in monitoring activity of the program. Condition/Context: In our audit, we noted the County submitted one Performance and Expenditure report after the April 30 deadline. Cause: The County did not have sufficient internal controls in place to ensure that required reporting was completed by the deadline. Effect: Without adequate controls over federal expenditures reporting, the County may not complete required reporting by the required deadlines. Questioned Costs: N/A Identification As A Repeat Finding: N/A Recommendation: We recommend the County improve its internal controls by ensuring the personnel responsible are appropriately trained and monitored on federal grant requirements. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Finding 2021-002 Allowable Costs and Allowable Activities Material Weakness Compliance And Internal Control Over Allowable Costs And Activities ALN 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Criteria Or Specific Requirement: 2 CFR 200.403(f) requires cost not being included or used for any other federally-financed program. Additionally, 2 CFR 200.430(i)(1)(i) requires entities to have personnel expenses supported by a system of internal controls which provide reasonable assurance that charges are accurate, allowable and properly allocated. Condition: In our audit, we noted 4 costs amounting to approximately $20,000 were previously reimbursed from another federal program in addition to ALN 21.027. Upon notification of the duplication, the County allocated replacement expenditures to ALN 21.027 to rectify the duplication. We also noted that 21 of 60 individual timecards that did not have documented review by an appropriate supervisor. A mitigating control of review of summary level of expenditures by the County Manager was in place. However, due to the nature of the expenditures, the detail review of time recorded was not consistently documented for our sample selections, and the mitigating controls did not prevent the duplication of the $20,000 of expenditure under two different federal programs. Cause: The County does not have an established policy to ensure that the review and approval of timecards of hourly employees is documented and the mitigating controls were not adequate to detect the duplications under the two programs. Effect: Without documentation of adequate controls over expenditures in compliance with requirements, the County was not able to detect an error in allowable costs. Questioned Costs: None Identification As A Repeat Finding: N/A Recommendation: We recommend that the County establish and follow a documented policy of review of timecards for all departments, as well as a detailed review of grant coding. The County should improve its internal controls over grants by ensuring the personnel responsible are appropriately documenting reviews and approvals related to the allowability and availability of expenditures to a specific grant program. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Finding 2021-003 Material Weakness, Inaccurate Schedule Of Expenditures Of Federal Awards (The SEFA) Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance) provides guidance related to preparation and reporting of a SEFA. 2 CFR Section 200.100 identifies the required elements of the SEFA and 2 CFR Section 200.510 specifically requires that the SEFA include information on each federal award expended during the year. The County is required to prepare a complete and accurate SEFA and to have a system of internal controls, the design and operation of which allows management or employees in the normal course of performing their assigned functions to prevent, or detect and correct, errors on a timely basis. Condition: The initial SEFA was inaccurate and was not updated from the prior year for several program, which led to errors in reporting federal awards. Cause: The County did not have adequate oversight in place for finance/accounting staff to ensure its SEFA was prepared in accordance with federal requirements. The County experienced significant turnover in several key management and finance/accounting roles in addition to some extended absences due to personal matters of key financial/accounting personnel. Effect: As a result of the errors, the SEFA was materially incorrect. Inaccurate identification of federal awards may also result in inaccurate identification of compliance requirements, risk assessments, major program determination, materiality determinations and reporting errors. Questioned Costs: None Context: N/A Identification As A Repeat Finding: N/A Recommendation: The County should strengthen its internal controls by implementing additional training and oversight of personnel to ensure the SEFA accurately reflects federal expenditures for the year. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Finding 2019-001 Significant Deficiency in Internal Control over Foster Care - Title IV-E (Foster Care) Special Tests and Provisions CFDA# 93.658 Federal Award Identification Number: Unavailable Federal Agency: Department of Health and Human Services Pass-Through Entity: Colorado Department of Human Services Criteria Or Specific Requirement: Foster Care maintenance payments are allowable only when established at a reasonable and specific amount for a time-limited period established by the Title IV-E agency to assure the rate?s continuing appropriateness for the administration of the Title IV-E program (42 USC 6719a)(11);45 CFR section 1356.21(m)(1); 45 CFR section 1356.60(a)(1) and (c)). Applicable maintenance rates should be paid in compliance with the allowable rates per the program. The County is expected to have internal controls over the rate determinations (special tests and provisions) process that ensures only appropriate rate is paid. Condition: The County did not have effective internal controls in place over Foster Care rate determinations for the Trails system for all periods of 2019. Cause: The related review of maintenance payment rates for the Trails system were not in place and in service for all periods of 2019. Effect: Due to insufficient monitoring and internal controls over compliance, the County may not timely detect an error in rate determinations related to the Trails system. Questioned Costs: None Context: The County has a process to review and approve rates outside of Trails; however, one of three selected case files tested did not have the documented controls for the Trails System. Identification As Repeat Finding: 2018-001, 2017-002

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