EIN: 946000501
UEI: ZK45GWUKWMH2
Audited by: Macias Gini & O'Connell LLP
Cognizant agency: 93 [Department of Health and Human Services]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 27, 2026 (27 days from today).
What is a management decision? →FAC accepted this audit on March 30, 2026 — management decision was due September 30, 2026.
FAC accepted this audit on March 30, 2026 — management decision was due September 30, 2026.
FAC accepted this audit on March 28, 2025 — management decision was due September 28, 2025.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
FAC accepted this audit on April 6, 2024 — management decision was due October 6, 2024.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
2022-003 - Cash Management and Reporting Material Noncompliance Material Weakness in Internal Controls Over Compliance Finding Reference: 2022-003 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-02-10 / COVID-19ELC59 Award Names: COVID-19 ELC Enhancing Detection Expansion Funding ? Coronavirus Response and Relief Supplemental Appropriations Act 2021 Criteria U.S. Code of Federal Regulations, Title 45, Part 75, section 75.303 Internal Controls, require the non-federal entity to: a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. The County manages the following grant with the California Department of Public Health (CDPH) under the Epidemiology and Laboratory Capacity for Infectious Diseases program under Assistance Listing Number 93.323: ? CDC - Epidemiology and Laboratory Capacity (ELC) Enhanced Detection Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; (ELC3) This grant is managed through the Alameda County Health Care Services Agency (HCSA). The County is required to submit a detailed budget in the Spend Plan and monthly expenditure reports that measure expenditures against the budget. Condition The HCSA used an internal tracking spreadsheet as the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH to track actual expenditures since the inception of the grants, and erroneously included encumbered costs in its tracking. Cumulative expenditures through June 30, 2022 amounted to $45.8 million, which included encumbrances. The spreadsheet was the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH. Accordingly, reported expenditures and claimed expenditures on a cumulative basis were both overstated by $12.6 million as of June 30, 2022. Cause The HCSA interpreted the monthly expenditure reporting requirements to include encumbered costs in the fiscal period of encumbrance. Reimbursement requests were prepared based on information from the monthly expenditure reports, and thus were also overstated. Effect Monthly expenditures reports and claims for reimbursements were cumulatively overstated by $12.6 million as of June 30, 2022. Questioned Costs Questioned costs of $12,583,345 represent the amount claimed above actual expenditures as of June 30, 2022. Recommendation We recommend that the HCSA take measures to adjust its monthly expenditure reports within the Spend Plan and the reimbursement claims to report actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴2022-003 - Cash Management and Reporting Material Noncompliance Material Weakness in Internal Controls Over Compliance Finding Reference: 2022-003 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-02-10 / COVID-19ELC59 Award Names: COVID-19 ELC Enhancing Detection Expansion Funding ? Coronavirus Response and Relief Supplemental Appropriations Act 2021 Criteria U.S. Code of Federal Regulations, Title 45, Part 75, section 75.303 Internal Controls, require the non-federal entity to: a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. The County manages the following grant with the California Department of Public Health (CDPH) under the Epidemiology and Laboratory Capacity for Infectious Diseases program under Assistance Listing Number 93.323: ? CDC - Epidemiology and Laboratory Capacity (ELC) Enhanced Detection Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; (ELC3) This grant is managed through the Alameda County Health Care Services Agency (HCSA). The County is required to submit a detailed budget in the Spend Plan and monthly expenditure reports that measure expenditures against the budget. Condition The HCSA used an internal tracking spreadsheet as the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH to track actual expenditures since the inception of the grants, and erroneously included encumbered costs in its tracking. Cumulative expenditures through June 30, 2022 amounted to $45.8 million, which included encumbrances. The spreadsheet was the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH. Accordingly, reported expenditures and claimed expenditures on a cumulative basis were both overstated by $12.6 million as of June 30, 2022. Cause The HCSA interpreted the monthly expenditure reporting requirements to include encumbered costs in the fiscal period of encumbrance. Reimbursement requests were prepared based on information from the monthly expenditure reports, and thus were also overstated. Effect Monthly expenditures reports and claims for reimbursements were cumulatively overstated by $12.6 million as of June 30, 2022. Questioned Costs Questioned costs of $12,583,345 represent the amount claimed above actual expenditures as of June 30, 2022. Recommendation We recommend that the HCSA take measures to adjust its monthly expenditure reports within the Spend Plan and the reimbursement claims to report actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2022-003 ? Cash Management and Reporting Material Noncompliance Material Weakness in Controls Over Compliance Responsible Party: Brian Lim Financial Services Specialist II HCSA Office of the Agency Director Corrective Action Plan: In meetings with the State, HCSA has clarified that encumbrances were submitted as part of the expenditure reporting and claiming and the State has expressed awareness of this reporting and claiming practice, but to date, HCSA has not been able to obtain documented confirmation that permitted reimbursing HCSA for encumbered amounts. HCSA will take measures to adjust monthly expenditure reports within the Spend Plan and include in the next soonest reporting and claim period actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. HCSA will resolve with CDPH previously claimed encumbrances and ensure alignment with expenditure reporting requirements and claims for reimbursement requirements. Anticipated Implementation Date: June 30, 2024
2021-002
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
2022-003 - Cash Management and Reporting Material Noncompliance Material Weakness in Internal Controls Over Compliance Finding Reference: 2022-003 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-02-10 / COVID-19ELC59 Award Names: COVID-19 ELC Enhancing Detection Expansion Funding ? Coronavirus Response and Relief Supplemental Appropriations Act 2021 Criteria U.S. Code of Federal Regulations, Title 45, Part 75, section 75.303 Internal Controls, require the non-federal entity to: a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. The County manages the following grant with the California Department of Public Health (CDPH) under the Epidemiology and Laboratory Capacity for Infectious Diseases program under Assistance Listing Number 93.323: ? CDC - Epidemiology and Laboratory Capacity (ELC) Enhanced Detection Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; (ELC3) This grant is managed through the Alameda County Health Care Services Agency (HCSA). The County is required to submit a detailed budget in the Spend Plan and monthly expenditure reports that measure expenditures against the budget. Condition The HCSA used an internal tracking spreadsheet as the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH to track actual expenditures since the inception of the grants, and erroneously included encumbered costs in its tracking. Cumulative expenditures through June 30, 2022 amounted to $45.8 million, which included encumbrances. The spreadsheet was the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH. Accordingly, reported expenditures and claimed expenditures on a cumulative basis were both overstated by $12.6 million as of June 30, 2022. Cause The HCSA interpreted the monthly expenditure reporting requirements to include encumbered costs in the fiscal period of encumbrance. Reimbursement requests were prepared based on information from the monthly expenditure reports, and thus were also overstated. Effect Monthly expenditures reports and claims for reimbursements were cumulatively overstated by $12.6 million as of June 30, 2022. Questioned Costs Questioned costs of $12,583,345 represent the amount claimed above actual expenditures as of June 30, 2022. Recommendation We recommend that the HCSA take measures to adjust its monthly expenditure reports within the Spend Plan and the reimbursement claims to report actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴2022-003 - Cash Management and Reporting Material Noncompliance Material Weakness in Internal Controls Over Compliance Finding Reference: 2022-003 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-02-10 / COVID-19ELC59 Award Names: COVID-19 ELC Enhancing Detection Expansion Funding ? Coronavirus Response and Relief Supplemental Appropriations Act 2021 Criteria U.S. Code of Federal Regulations, Title 45, Part 75, section 75.303 Internal Controls, require the non-federal entity to: a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. The County manages the following grant with the California Department of Public Health (CDPH) under the Epidemiology and Laboratory Capacity for Infectious Diseases program under Assistance Listing Number 93.323: ? CDC - Epidemiology and Laboratory Capacity (ELC) Enhanced Detection Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; (ELC3) This grant is managed through the Alameda County Health Care Services Agency (HCSA). The County is required to submit a detailed budget in the Spend Plan and monthly expenditure reports that measure expenditures against the budget. Condition The HCSA used an internal tracking spreadsheet as the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH to track actual expenditures since the inception of the grants, and erroneously included encumbered costs in its tracking. Cumulative expenditures through June 30, 2022 amounted to $45.8 million, which included encumbrances. The spreadsheet was the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH. Accordingly, reported expenditures and claimed expenditures on a cumulative basis were both overstated by $12.6 million as of June 30, 2022. Cause The HCSA interpreted the monthly expenditure reporting requirements to include encumbered costs in the fiscal period of encumbrance. Reimbursement requests were prepared based on information from the monthly expenditure reports, and thus were also overstated. Effect Monthly expenditures reports and claims for reimbursements were cumulatively overstated by $12.6 million as of June 30, 2022. Questioned Costs Questioned costs of $12,583,345 represent the amount claimed above actual expenditures as of June 30, 2022. Recommendation We recommend that the HCSA take measures to adjust its monthly expenditure reports within the Spend Plan and the reimbursement claims to report actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2022-003 ? Cash Management and Reporting Material Noncompliance Material Weakness in Controls Over Compliance Responsible Party: Brian Lim Financial Services Specialist II HCSA Office of the Agency Director Corrective Action Plan: In meetings with the State, HCSA has clarified that encumbrances were submitted as part of the expenditure reporting and claiming and the State has expressed awareness of this reporting and claiming practice, but to date, HCSA has not been able to obtain documented confirmation that permitted reimbursing HCSA for encumbered amounts. HCSA will take measures to adjust monthly expenditure reports within the Spend Plan and include in the next soonest reporting and claim period actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. HCSA will resolve with CDPH previously claimed encumbrances and ensure alignment with expenditure reporting requirements and claims for reimbursement requirements. Anticipated Implementation Date: June 30, 2024
2021-002
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
2022-003 - Cash Management and Reporting Material Noncompliance Material Weakness in Internal Controls Over Compliance Finding Reference: 2022-003 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-02-10 / COVID-19ELC59 Award Names: COVID-19 ELC Enhancing Detection Expansion Funding ? Coronavirus Response and Relief Supplemental Appropriations Act 2021 Criteria U.S. Code of Federal Regulations, Title 45, Part 75, section 75.303 Internal Controls, require the non-federal entity to: a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. The County manages the following grant with the California Department of Public Health (CDPH) under the Epidemiology and Laboratory Capacity for Infectious Diseases program under Assistance Listing Number 93.323: ? CDC - Epidemiology and Laboratory Capacity (ELC) Enhanced Detection Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; (ELC3) This grant is managed through the Alameda County Health Care Services Agency (HCSA). The County is required to submit a detailed budget in the Spend Plan and monthly expenditure reports that measure expenditures against the budget. Condition The HCSA used an internal tracking spreadsheet as the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH to track actual expenditures since the inception of the grants, and erroneously included encumbered costs in its tracking. Cumulative expenditures through June 30, 2022 amounted to $45.8 million, which included encumbrances. The spreadsheet was the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH. Accordingly, reported expenditures and claimed expenditures on a cumulative basis were both overstated by $12.6 million as of June 30, 2022. Cause The HCSA interpreted the monthly expenditure reporting requirements to include encumbered costs in the fiscal period of encumbrance. Reimbursement requests were prepared based on information from the monthly expenditure reports, and thus were also overstated. Effect Monthly expenditures reports and claims for reimbursements were cumulatively overstated by $12.6 million as of June 30, 2022. Questioned Costs Questioned costs of $12,583,345 represent the amount claimed above actual expenditures as of June 30, 2022. Recommendation We recommend that the HCSA take measures to adjust its monthly expenditure reports within the Spend Plan and the reimbursement claims to report actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴2022-003 - Cash Management and Reporting Material Noncompliance Material Weakness in Internal Controls Over Compliance Finding Reference: 2022-003 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-02-10 / COVID-19ELC59 Award Names: COVID-19 ELC Enhancing Detection Expansion Funding ? Coronavirus Response and Relief Supplemental Appropriations Act 2021 Criteria U.S. Code of Federal Regulations, Title 45, Part 75, section 75.303 Internal Controls, require the non-federal entity to: a) 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 statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government,? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards. c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. The County manages the following grant with the California Department of Public Health (CDPH) under the Epidemiology and Laboratory Capacity for Infectious Diseases program under Assistance Listing Number 93.323: ? CDC - Epidemiology and Laboratory Capacity (ELC) Enhanced Detection Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; (ELC3) This grant is managed through the Alameda County Health Care Services Agency (HCSA). The County is required to submit a detailed budget in the Spend Plan and monthly expenditure reports that measure expenditures against the budget. Condition The HCSA used an internal tracking spreadsheet as the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH to track actual expenditures since the inception of the grants, and erroneously included encumbered costs in its tracking. Cumulative expenditures through June 30, 2022 amounted to $45.8 million, which included encumbrances. The spreadsheet was the basis for the monthly expenditure reports and claims for reimbursement submitted to CDPH. Accordingly, reported expenditures and claimed expenditures on a cumulative basis were both overstated by $12.6 million as of June 30, 2022. Cause The HCSA interpreted the monthly expenditure reporting requirements to include encumbered costs in the fiscal period of encumbrance. Reimbursement requests were prepared based on information from the monthly expenditure reports, and thus were also overstated. Effect Monthly expenditures reports and claims for reimbursements were cumulatively overstated by $12.6 million as of June 30, 2022. Questioned Costs Questioned costs of $12,583,345 represent the amount claimed above actual expenditures as of June 30, 2022. Recommendation We recommend that the HCSA take measures to adjust its monthly expenditure reports within the Spend Plan and the reimbursement claims to report actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2022-003 ? Cash Management and Reporting Material Noncompliance Material Weakness in Controls Over Compliance Responsible Party: Brian Lim Financial Services Specialist II HCSA Office of the Agency Director Corrective Action Plan: In meetings with the State, HCSA has clarified that encumbrances were submitted as part of the expenditure reporting and claiming and the State has expressed awareness of this reporting and claiming practice, but to date, HCSA has not been able to obtain documented confirmation that permitted reimbursing HCSA for encumbered amounts. HCSA will take measures to adjust monthly expenditure reports within the Spend Plan and include in the next soonest reporting and claim period actual expenditures, and revisit grant award provisions pertaining to reporting requirements to ensure that both the reports and the claims are prepared using the appropriate basis of accounting. HCSA will resolve with CDPH previously claimed encumbrances and ensure alignment with expenditure reporting requirements and claims for reimbursement requirements. Anticipated Implementation Date: June 30, 2024
2021-002
FAC accepted this audit on May 9, 2022 — management decision was due November 9, 2022.
Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Finding Reference: 2021-001 Federal Agency: Election Assistance Commission Pass-Through Agency: None Federal Program Title: 2018 HAVA Election Security Grants Federal Catalog Number: 90.404 Federal Grant Numbers: 20G26101 Award Names: 2018 HAVA Election Security Grants Criterion Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, states that non-federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement 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 non-procurement transactions entered into by a pass-through entity (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. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the entity for active exclusions at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition The 2018 HAVA Election Security Grants program is administered by the County Registrar of Voters. While the County has a procurement policy that addresses compliance with federal suspension and debarment requirements, the County?s direct claiming mechanism does not specifically address federal regulations. The direct claiming mechanism is intended for expedited contracting for certain higher priority goods and services, including election expenditures. The Registrar of Voters used the direct claiming method to procure goods and services funded by the program for the year ended June 30, 2021. Our sample of $2,000,284 from a population of $2,825,763 in procured goods and services included $526,733 (or 26%) that were procured using the direct claiming method and were not subject to suspension and debarment verification before the covered transactions were executed. However, subsequent verifications on SAM.gov confirmed that none of the parties in the sampled transactions were suspended or debarred during the contract periods. Cause Program personnel were not aware of the requirement to check for suspension and debarment. Effect The use of the existing direct claiming method for federally funded transactions puts the County at risk of noncompliance with applicable federal procurement requirements. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the County revisit its procurement policies and procedures, including the use of the direct claiming method, to ensure federally funded transactions follow applicable procurement requirements for federal awards. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Finding Reference: 2021-001 Federal Agency: Election Assistance Commission Pass-Through Agency: None Federal Program Title: 2018 HAVA Election Security Grants Federal Catalog Number: 90.404 Federal Grant Numbers: 20G26101 Award Names: 2018 HAVA Election Security Grants Criterion Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, states that non-federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement 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 non-procurement transactions entered into by a pass-through entity (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. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the entity for active exclusions at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition The 2018 HAVA Election Security Grants program is administered by the County Registrar of Voters. While the County has a procurement policy that addresses compliance with federal suspension and debarment requirements, the County?s direct claiming mechanism does not specifically address federal regulations. The direct claiming mechanism is intended for expedited contracting for certain higher priority goods and services, including election expenditures. The Registrar of Voters used the direct claiming method to procure goods and services funded by the program for the year ended June 30, 2021. Our sample of $2,000,284 from a population of $2,825,763 in procured goods and services included $526,733 (or 26%) that were procured using the direct claiming method and were not subject to suspension and debarment verification before the covered transactions were executed. However, subsequent verifications on SAM.gov confirmed that none of the parties in the sampled transactions were suspended or debarred during the contract periods. Cause Program personnel were not aware of the requirement to check for suspension and debarment. Effect The use of the existing direct claiming method for federally funded transactions puts the County at risk of noncompliance with applicable federal procurement requirements. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the County revisit its procurement policies and procedures, including the use of the direct claiming method, to ensure federally funded transactions follow applicable procurement requirements for federal awards. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Responsible Party: Cynthia Cornejo Deputy Registrar of Voters Alameda County Registrar of Voters Dwayna Gullatt Elections Technician Alameda County Registrar of Voters Corrective Action Plan: In order to ensure that a vendor is not suspended or debarred or otherwise excluded from participating in a transaction, the plan for corrective action to the finding of noncompliance of Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, Alameda County Registrar of Voters (ROV) will (1) check the System for Award Management (SAM) at https://www.sam.gov/SAM/ for all entities, prior to requesting a purchase. (2) If an entity has been suspended or debarred, ROV will not follow through with a transaction. (3) Proof of non-suspension or non-debarment is required as the initial step for a purchase request. (4) The purchase request packet must include proof of non-suspension or non-debarment for all entities. (5) Proof of the non-suspension or non-debarment includes a current printout indicating ?No Match Found? from the search page on https://www.sam.gov/SAM/ for each entity. Anticipated Implementation Date: May 31, 2022
Item No. 2021-002 ? Reporting Significant Deficiency Finding Reference: 2021-002 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-01-10; 6 NU50CK000539-02-07 Award Names: CDC - Epidemiology and Laboratory Capacity (ELC) Paycheck Protection Program and Health Care Enhancement Act of 2020; CDC - Epidemiology and Laboratory Capacity (ELC) Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; Criterion Code of Federal Regulations, Title 2 ? Subtitle A, Part 200, Subpart D, Section 200.334 Retention requirements for records requires ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Condition The Epidemiology and Laboratory Capacity for Infectious Diseases program is administered by the County Health Care Services Agency ? Department of Public Health. Under the provisions of the grant agreements for the program, the County is required to submit quarterly expenditure and quarterly progress reports. The County did not have a process to retain proper documentation of report submission or evidence of proper review and approval of the reports. However, the County?s Information Technology Department was able to retrieve evidence of report submission from archived emails. Cause The County did not have a process to retain proper documentation. The individual who submitted the reports during the year ended June 30, 2021 left County employment. The new personnel overseeing this process did not have access to the applicable documentation. Effect The lack of proper documentation puts the County at risk for being unable to substantiate compliance with applicable requirements for federal awards. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the Health Care Services Agency ? Department of Public Health strengthen its internal controls over record retention related to reporting requirements to ensure that documentation is maintained in a designated place for the required period to clearly demonstrate compliance with program requirements and that established controls were followed. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Item No. 2021-002 ? Reporting Significant Deficiency Finding Reference: 2021-002 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-01-10; 6 NU50CK000539-02-07 Award Names: CDC - Epidemiology and Laboratory Capacity (ELC) Paycheck Protection Program and Health Care Enhancement Act of 2020; CDC - Epidemiology and Laboratory Capacity (ELC) Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; Criterion Code of Federal Regulations, Title 2 ? Subtitle A, Part 200, Subpart D, Section 200.334 Retention requirements for records requires ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Condition The Epidemiology and Laboratory Capacity for Infectious Diseases program is administered by the County Health Care Services Agency ? Department of Public Health. Under the provisions of the grant agreements for the program, the County is required to submit quarterly expenditure and quarterly progress reports. The County did not have a process to retain proper documentation of report submission or evidence of proper review and approval of the reports. However, the County?s Information Technology Department was able to retrieve evidence of report submission from archived emails. Cause The County did not have a process to retain proper documentation. The individual who submitted the reports during the year ended June 30, 2021 left County employment. The new personnel overseeing this process did not have access to the applicable documentation. Effect The lack of proper documentation puts the County at risk for being unable to substantiate compliance with applicable requirements for federal awards. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the Health Care Services Agency ? Department of Public Health strengthen its internal controls over record retention related to reporting requirements to ensure that documentation is maintained in a designated place for the required period to clearly demonstrate compliance with program requirements and that established controls were followed. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2021-002 ? Reporting Significant Deficiency Responsible Party: ThuTrang Hoang Supervising Financial Services Specialist Public Health Department Billing & Grants Claiming Unit Corrective Action Plan: The Public Health Department (PHD) agrees with the recommendations. PHD will retain records of quarterly reports submitted to the state awarding agency, evidence of timely submission, and documentation of review/approval of such reports within PHD. PHD will document these internal control measures in its written procedures, which will include the location of the records as well as the duration of retention. Anticipated Implementation Date: August 1, 2022
FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.
Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Finding Reference: 2021-001 Federal Agency: Election Assistance Commission Pass-Through Agency: None Federal Program Title: 2018 HAVA Election Security Grants Federal Catalog Number: 90.404 Federal Grant Numbers: 20G26101 Award Names: 2018 HAVA Election Security Grants Criterion Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, states that non-federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement 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 non-procurement transactions entered into by a pass-through entity (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. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the entity for active exclusions at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition The 2018 HAVA Election Security Grants program is administered by the County Registrar of Voters. While the County has a procurement policy that addresses compliance with federal suspension and debarment requirements, the County?s direct claiming mechanism does not specifically address federal regulations. The direct claiming mechanism is intended for expedited contracting for certain higher priority goods and services, including election expenditures. The Registrar of Voters used the direct claiming method to procure goods and services funded by the program for the year ended June 30, 2021. Our sample of $2,000,284 from a population of $2,825,763 in procured goods and services included $526,733 (or 26%) that were procured using the direct claiming method and were not subject to suspension and debarment verification before the covered transactions were executed. However, subsequent verifications on SAM.gov confirmed that none of the parties in the sampled transactions were suspended or debarred during the contract periods. Cause Program personnel were not aware of the requirement to check for suspension and debarment. Effect The use of the existing direct claiming method for federally funded transactions puts the County at risk of noncompliance with applicable federal procurement requirements. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the County revisit its procurement policies and procedures, including the use of the direct claiming method, to ensure federally funded transactions follow applicable procurement requirements for federal awards. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Finding Reference: 2021-001 Federal Agency: Election Assistance Commission Pass-Through Agency: None Federal Program Title: 2018 HAVA Election Security Grants Federal Catalog Number: 90.404 Federal Grant Numbers: 20G26101 Award Names: 2018 HAVA Election Security Grants Criterion Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, states that non-federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement 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 non-procurement transactions entered into by a pass-through entity (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. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the entity for active exclusions at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition The 2018 HAVA Election Security Grants program is administered by the County Registrar of Voters. While the County has a procurement policy that addresses compliance with federal suspension and debarment requirements, the County?s direct claiming mechanism does not specifically address federal regulations. The direct claiming mechanism is intended for expedited contracting for certain higher priority goods and services, including election expenditures. The Registrar of Voters used the direct claiming method to procure goods and services funded by the program for the year ended June 30, 2021. Our sample of $2,000,284 from a population of $2,825,763 in procured goods and services included $526,733 (or 26%) that were procured using the direct claiming method and were not subject to suspension and debarment verification before the covered transactions were executed. However, subsequent verifications on SAM.gov confirmed that none of the parties in the sampled transactions were suspended or debarred during the contract periods. Cause Program personnel were not aware of the requirement to check for suspension and debarment. Effect The use of the existing direct claiming method for federally funded transactions puts the County at risk of noncompliance with applicable federal procurement requirements. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the County revisit its procurement policies and procedures, including the use of the direct claiming method, to ensure federally funded transactions follow applicable procurement requirements for federal awards. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Responsible Party: Cynthia Cornejo Deputy Registrar of Voters Alameda County Registrar of Voters Dwayna Gullatt Elections Technician Alameda County Registrar of Voters Corrective Action Plan: In order to ensure that a vendor is not suspended or debarred or otherwise excluded from participating in a transaction, the plan for corrective action to the finding of noncompliance of Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, Alameda County Registrar of Voters (ROV) will (1) check the System for Award Management (SAM) at https://www.sam.gov/SAM/ for all entities, prior to requesting a purchase. (2) If an entity has been suspended or debarred, ROV will not follow through with a transaction. (3) Proof of non-suspension or non-debarment is required as the initial step for a purchase request. (4) The purchase request packet must include proof of non-suspension or non-debarment for all entities. (5) Proof of the non-suspension or non-debarment includes a current printout indicating ?No Match Found? from the search page on https://www.sam.gov/SAM/ for each entity. Anticipated Implementation Date: May 31, 2022
Item No. 2021-002 ? Reporting Significant Deficiency Finding Reference: 2021-002 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-01-10; 6 NU50CK000539-02-07 Award Names: CDC - Epidemiology and Laboratory Capacity (ELC) Paycheck Protection Program and Health Care Enhancement Act of 2020; CDC - Epidemiology and Laboratory Capacity (ELC) Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; Criterion Code of Federal Regulations, Title 2 ? Subtitle A, Part 200, Subpart D, Section 200.334 Retention requirements for records requires ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Condition The Epidemiology and Laboratory Capacity for Infectious Diseases program is administered by the County Health Care Services Agency ? Department of Public Health. Under the provisions of the grant agreements for the program, the County is required to submit quarterly expenditure and quarterly progress reports. The County did not have a process to retain proper documentation of report submission or evidence of proper review and approval of the reports. However, the County?s Information Technology Department was able to retrieve evidence of report submission from archived emails. Cause The County did not have a process to retain proper documentation. The individual who submitted the reports during the year ended June 30, 2021 left County employment. The new personnel overseeing this process did not have access to the applicable documentation. Effect The lack of proper documentation puts the County at risk for being unable to substantiate compliance with applicable requirements for federal awards. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the Health Care Services Agency ? Department of Public Health strengthen its internal controls over record retention related to reporting requirements to ensure that documentation is maintained in a designated place for the required period to clearly demonstrate compliance with program requirements and that established controls were followed. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Item No. 2021-002 ? Reporting Significant Deficiency Finding Reference: 2021-002 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-01-10; 6 NU50CK000539-02-07 Award Names: CDC - Epidemiology and Laboratory Capacity (ELC) Paycheck Protection Program and Health Care Enhancement Act of 2020; CDC - Epidemiology and Laboratory Capacity (ELC) Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; Criterion Code of Federal Regulations, Title 2 ? Subtitle A, Part 200, Subpart D, Section 200.334 Retention requirements for records requires ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Condition The Epidemiology and Laboratory Capacity for Infectious Diseases program is administered by the County Health Care Services Agency ? Department of Public Health. Under the provisions of the grant agreements for the program, the County is required to submit quarterly expenditure and quarterly progress reports. The County did not have a process to retain proper documentation of report submission or evidence of proper review and approval of the reports. However, the County?s Information Technology Department was able to retrieve evidence of report submission from archived emails. Cause The County did not have a process to retain proper documentation. The individual who submitted the reports during the year ended June 30, 2021 left County employment. The new personnel overseeing this process did not have access to the applicable documentation. Effect The lack of proper documentation puts the County at risk for being unable to substantiate compliance with applicable requirements for federal awards. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the Health Care Services Agency ? Department of Public Health strengthen its internal controls over record retention related to reporting requirements to ensure that documentation is maintained in a designated place for the required period to clearly demonstrate compliance with program requirements and that established controls were followed. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2021-002 ? Reporting Significant Deficiency Responsible Party: ThuTrang Hoang Supervising Financial Services Specialist Public Health Department Billing & Grants Claiming Unit Corrective Action Plan: The Public Health Department (PHD) agrees with the recommendations. PHD will retain records of quarterly reports submitted to the state awarding agency, evidence of timely submission, and documentation of review/approval of such reports within PHD. PHD will document these internal control measures in its written procedures, which will include the location of the records as well as the duration of retention. Anticipated Implementation Date: August 1, 2022
FAC accepted this audit on March 30, 2022 — management decision was due September 30, 2022.
Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Finding Reference: 2021-001 Federal Agency: Election Assistance Commission Pass-Through Agency: None Federal Program Title: 2018 HAVA Election Security Grants Federal Catalog Number: 90.404 Federal Grant Numbers: 20G26101 Award Names: 2018 HAVA Election Security Grants Criterion Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, states that non-federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement 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 non-procurement transactions entered into by a pass-through entity (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. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the entity for active exclusions at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition The 2018 HAVA Election Security Grants program is administered by the County Registrar of Voters. While the County has a procurement policy that addresses compliance with federal suspension and debarment requirements, the County?s direct claiming mechanism does not specifically address federal regulations. The direct claiming mechanism is intended for expedited contracting for certain higher priority goods and services, including election expenditures. The Registrar of Voters used the direct claiming method to procure goods and services funded by the program for the year ended June 30, 2021. Our sample of $2,000,284 from a population of $2,825,763 in procured goods and services included $526,733 (or 26%) that were procured using the direct claiming method and were not subject to suspension and debarment verification before the covered transactions were executed. However, subsequent verifications on SAM.gov confirmed that none of the parties in the sampled transactions were suspended or debarred during the contract periods. Cause Program personnel were not aware of the requirement to check for suspension and debarment. Effect The use of the existing direct claiming method for federally funded transactions puts the County at risk of noncompliance with applicable federal procurement requirements. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the County revisit its procurement policies and procedures, including the use of the direct claiming method, to ensure federally funded transactions follow applicable procurement requirements for federal awards. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Finding Reference: 2021-001 Federal Agency: Election Assistance Commission Pass-Through Agency: None Federal Program Title: 2018 HAVA Election Security Grants Federal Catalog Number: 90.404 Federal Grant Numbers: 20G26101 Award Names: 2018 HAVA Election Security Grants Criterion Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, states that non-federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement 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 non-procurement transactions entered into by a pass-through entity (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. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the entity for active exclusions at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity. Condition The 2018 HAVA Election Security Grants program is administered by the County Registrar of Voters. While the County has a procurement policy that addresses compliance with federal suspension and debarment requirements, the County?s direct claiming mechanism does not specifically address federal regulations. The direct claiming mechanism is intended for expedited contracting for certain higher priority goods and services, including election expenditures. The Registrar of Voters used the direct claiming method to procure goods and services funded by the program for the year ended June 30, 2021. Our sample of $2,000,284 from a population of $2,825,763 in procured goods and services included $526,733 (or 26%) that were procured using the direct claiming method and were not subject to suspension and debarment verification before the covered transactions were executed. However, subsequent verifications on SAM.gov confirmed that none of the parties in the sampled transactions were suspended or debarred during the contract periods. Cause Program personnel were not aware of the requirement to check for suspension and debarment. Effect The use of the existing direct claiming method for federally funded transactions puts the County at risk of noncompliance with applicable federal procurement requirements. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the County revisit its procurement policies and procedures, including the use of the direct claiming method, to ensure federally funded transactions follow applicable procurement requirements for federal awards. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2021-001 ? Procurement, Suspension and Debarment Material Weakness Responsible Party: Cynthia Cornejo Deputy Registrar of Voters Alameda County Registrar of Voters Dwayna Gullatt Elections Technician Alameda County Registrar of Voters Corrective Action Plan: In order to ensure that a vendor is not suspended or debarred or otherwise excluded from participating in a transaction, the plan for corrective action to the finding of noncompliance of Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 200, Subpart C, Section 200.213, Suspension and Debarment, Alameda County Registrar of Voters (ROV) will (1) check the System for Award Management (SAM) at https://www.sam.gov/SAM/ for all entities, prior to requesting a purchase. (2) If an entity has been suspended or debarred, ROV will not follow through with a transaction. (3) Proof of non-suspension or non-debarment is required as the initial step for a purchase request. (4) The purchase request packet must include proof of non-suspension or non-debarment for all entities. (5) Proof of the non-suspension or non-debarment includes a current printout indicating ?No Match Found? from the search page on https://www.sam.gov/SAM/ for each entity. Anticipated Implementation Date: May 31, 2022
Item No. 2021-002 ? Reporting Significant Deficiency Finding Reference: 2021-002 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-01-10; 6 NU50CK000539-02-07 Award Names: CDC - Epidemiology and Laboratory Capacity (ELC) Paycheck Protection Program and Health Care Enhancement Act of 2020; CDC - Epidemiology and Laboratory Capacity (ELC) Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; Criterion Code of Federal Regulations, Title 2 ? Subtitle A, Part 200, Subpart D, Section 200.334 Retention requirements for records requires ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Condition The Epidemiology and Laboratory Capacity for Infectious Diseases program is administered by the County Health Care Services Agency ? Department of Public Health. Under the provisions of the grant agreements for the program, the County is required to submit quarterly expenditure and quarterly progress reports. The County did not have a process to retain proper documentation of report submission or evidence of proper review and approval of the reports. However, the County?s Information Technology Department was able to retrieve evidence of report submission from archived emails. Cause The County did not have a process to retain proper documentation. The individual who submitted the reports during the year ended June 30, 2021 left County employment. The new personnel overseeing this process did not have access to the applicable documentation. Effect The lack of proper documentation puts the County at risk for being unable to substantiate compliance with applicable requirements for federal awards. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the Health Care Services Agency ? Department of Public Health strengthen its internal controls over record retention related to reporting requirements to ensure that documentation is maintained in a designated place for the required period to clearly demonstrate compliance with program requirements and that established controls were followed. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Item No. 2021-002 ? Reporting Significant Deficiency Finding Reference: 2021-002 Federal Agency: United States Department of Health and Human Services Pass-Through Agency: California Department of Public Health Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Catalog Number: 93.323 Federal Grant Numbers: 6 NU50CK000539-01-10; 6 NU50CK000539-02-07 Award Names: CDC - Epidemiology and Laboratory Capacity (ELC) Paycheck Protection Program and Health Care Enhancement Act of 2020; CDC - Epidemiology and Laboratory Capacity (ELC) Expansion Coronavirus Response and Relief Supplemental Appropriations Act, 2021; Criterion Code of Federal Regulations, Title 2 ? Subtitle A, Part 200, Subpart D, Section 200.334 Retention requirements for records requires ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Condition The Epidemiology and Laboratory Capacity for Infectious Diseases program is administered by the County Health Care Services Agency ? Department of Public Health. Under the provisions of the grant agreements for the program, the County is required to submit quarterly expenditure and quarterly progress reports. The County did not have a process to retain proper documentation of report submission or evidence of proper review and approval of the reports. However, the County?s Information Technology Department was able to retrieve evidence of report submission from archived emails. Cause The County did not have a process to retain proper documentation. The individual who submitted the reports during the year ended June 30, 2021 left County employment. The new personnel overseeing this process did not have access to the applicable documentation. Effect The lack of proper documentation puts the County at risk for being unable to substantiate compliance with applicable requirements for federal awards. Questioned Costs There are no questioned costs associated with this finding. Recommendation We recommend that the Health Care Services Agency ? Department of Public Health strengthen its internal controls over record retention related to reporting requirements to ensure that documentation is maintained in a designated place for the required period to clearly demonstrate compliance with program requirements and that established controls were followed. View of Responsible Officials Management?s response is reported in a separate section at the end of this report.
Item No. 2021-002 ? Reporting Significant Deficiency Responsible Party: ThuTrang Hoang Supervising Financial Services Specialist Public Health Department Billing & Grants Claiming Unit Corrective Action Plan: The Public Health Department (PHD) agrees with the recommendations. PHD will retain records of quarterly reports submitted to the state awarding agency, evidence of timely submission, and documentation of review/approval of such reports within PHD. PHD will document these internal control measures in its written procedures, which will include the location of the records as well as the duration of retention. Anticipated Implementation Date: August 1, 2022
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
FAC accepted this audit on May 6, 2021 — management decision was due November 6, 2021.
FAC accepted this audit on March 19, 2020 — management decision was due September 19, 2020.
FAC accepted this audit on March 26, 2020 — management decision was due September 26, 2020.
FAC accepted this audit on March 18, 2020 — management decision was due September 18, 2020.
FAC accepted this audit on March 10, 2019 — management decision was due September 10, 2019.
FAC accepted this audit on March 17, 2019 — management decision was due September 17, 2019.
FAC accepted this audit on March 19, 2019 — management decision was due September 19, 2019.
FAC accepted this audit on March 25, 2019 — management decision was due September 25, 2019.
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
FAC accepted this audit on February 7, 2018 — management decision was due August 7, 2018.
FAC accepted this audit on February 27, 2018 — management decision was due August 27, 2018.
FAC accepted this audit on March 6, 2017 — management decision was due September 6, 2017.
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FAC accepted this audit on February 19, 2017 — management decision was due August 19, 2017.
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on March 1, 2017 — management decision was due September 1, 2017.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
2015-001
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
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