Tillamook CountyLocal Government

Criteria: 2 CRF 200.303(a) states: The non-Federal Entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. Condition: The County did not maintain effective internal control over the period of performance compliance requirement resulting in costs being charged to the grant that were incurred before the effective date of the grant and the total amount of costs charged exceeded the award amount. Cause: The information and communication systems at the County Health Department did not include the award amount or the effective date of the grant. Effect: Costs were charged to the grant that were incurred before the effective date of the grant in the amount of $26,975. Questioned Costs: $78,799. The total award for the grant was $252,167 and costs of $400,343 were charged to the grant. Of the amount charged to the grant $226,975 was ineligible as it was incurred prior to the effective date of the grant. The remaining costs of $173,368 were allowable under the grant. Accordingly the total award of $252,197 less $173,368 results in questioned costs of $78,799. Perspective: The Oregon State Health Authority has allowed the $78,799 to be carried over to a new grant period beginning July 1, 2021. Recommendations: Internal Controls should include a review of costs reported on grants to ensure they are incurred after the effective date of the grant and cumulative costs should not be greater than the total award amount. View of responsible officials: The County agrees with the finding and will develop a corrective action plan.

Criteria: CFR ?200.331(d) states: All pass-through entities must?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward goals are achieved. Pass- through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. Condition: The County did not perform subrecipient monitoring of the Tillamook Family Counseling Center (a not-for-profit organization) that received the subward. Cause: The County was not aware of the requirement to monitor the subrecipient. Effect: Unallowed activities could be undertaken or unallowed costs could be claimed under the program. Questioned Costs: None. Perspective: The program was new to the County and was received from the Oregon Health Authority (OHA). The Federal award was passed-through entirely to the Tillamook Family Counseling Center that takes responsibility for requesting funds directly from OHA without involvement by the County. Prior Finding: No. Recommendations: ?200.331(e) states that performing on-site reviews of the subrecipient's operations or arranging for agreed-upon procedures engagements may be useful tools for monitoring subrecipients. Views of Officials: The County agrees with the findings and will develop a corrective action plan to implement subrecipient monitoring of Tillamook Family Counseling Center.

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