COUNTY OF SOLANOLocal Government

Program: Medicaid Cluster - Grants to States for Medicaid, Medicaid Cluster - In-Home Supportive Services (IHSS)) Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Health Care Services Award Number and Year: 2305CA5MAP, 2505CA5MAP, 1946001347 A7, 2024/2025 Compliance Requirement: Eligibility Type of Finding: Material Instance of Noncompliance and Material Weakness in Internal Control over Compliance Criteria: Per the 2025 OMB Compliance Supplement, agencies are required to maintain documentation to support the agency’s eligibility determination, and to redetermine eligibility at least every 12 months to determine if individuals continue to be eligible in accordance with the compliance requirements of the program. In addition, the State of California Department of Social Services (CDSS) regulations also state that County’s social services staff are to have a face-to-face contact at least once every 12 months, except as provided in MPP section 30-761.215 through 30-761.217, to adequately determine that the recipient continues to reside safely in their home with the IHSS services provided (MPP Section 30-761.13). Condition: Medicaid Cluster – Grants to States for Medicaid • Of the 60 case files sampled, we noted 1 (one) case where the recipient eligibility redetermination was not performed timely and exceeded the 12-month requirement. Medicaid Cluster – In-Home Supportive Services (IHSS) • Of the 60 case files sampled, we noted 23 (twenty-three) cases where the recipient eligibility redetermination was not performed timely and exceeded the 12-month requirement. • 1 case in which the redetermination form was missing the appropriate signatures. Cause: The County’s policies and procedures did not ensure that timely redeterminations are performed for all program recipients. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 60 in-home supportive services case files were selected out of 6,960 case files. A nonstatistical sample of 60 medical assistance case files were selected out of 157,262 case files. Repeat Finding from Prior Year(s): Yes. See prior year finding 2024-005. Recommendation: We recommend that County implement policies and procedures to ensure eligibility redeterminations are performed on a timely basis and that proper documentation is maintained in case files. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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: We found that although the County performed a risk assessment and monitoring plan for its subrecipient, adherence to the plan was not documented. Pursuant to the County’s risk assessment of the subrecipient, a site visit was required, and quarterly reports were required to be obtained. The County did not formally document and communicate the results of the site visit performed during the year. The County also did not obtain the quarterly reports for the fiscal year until September 5th of the subsequent fiscal year. Further, there was no documented review of the quarterly reports by the County. Cause: Subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-002. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that that the results of monitoring procedures are documented and reviewed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2023/2024 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,506,689 $3,506,689 $3,506,689 $3,506,689 $3,506,689 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-003. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our special tests and provisions testing, we noted three (3) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the Rights, Responsibilities, and Important Information (form SAWS 2A SAR) for support the applicants initial interview application. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. The County’s policies and procedures did not ensure that all SAWS 2A SAR forms were retained with signatures in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In three (3) out of 60 cases, we found that the County did not retain a copy of the CW2.1 to evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 24,879 were selected for testing. This represented $103,835 of benefit payments out of $24,429,964. In one (1) out of 60 cases, we found that the County did not retain a copy of the SAWS 2A SAR to evidence the applicants’ rights and responsibilities. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2023-004. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Health Care Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 28 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. We also identified 3 instances out of 60 sampled in which the redetermination for participants was not completed, but they were still determined as eligible within the system and therefore continued to receive benefits. Cause: The County’s policies and procedures did not ensure that timely redeterminations are performed for all program recipients. Additionally, the County had been in the process of migrating to CalSAW and there were system issues causing cases to not be discontinued after they should have been determined as ineligible. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 6,215. A sample of 60 Medicaid recipients were selected out of 161,732. Repeat Finding from Prior Year(s): Yes. See prior year finding 2023-008. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified the following: 1. Five (5) instances out of 60 cases were missing all eligibility documentation. This included the documentation of the determination of eligibility and redetermination in the period under audit. The missing documentation included the records to evidence compliance with the eligibility criteria. 2. Two (2) instances out of 60 cases were missing the Self Declaration Statement form when the applicant was unable to provide acceptable documentation for proof of income, proof of address, or proof of identification. Cause: The County relies on the State of California Department of Public Health eligibility and documentation system, Women, Infant, and Children Web Information System Exchange (WIC WISE) to retain the case records. Management stated that WIC WISE automatically deletes the documentation for children 6 months after the child reaches 5 years old, and therefore was not available for the selected cases. The County’s policies and procedures did not ensure that the Self Declaration Statements were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 60 program participants out of a population of 9,060 were selected for testing. The five (5) and two (2) instances identified in the condition section above were part of the same population of 60 participants. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to retain documentation to evidence its compliance with program eligibility requirements for those documents which will not be retained in WIC WISE. We also recommend that the county strengthen its current policies and procedures with regards to obtaining the required forms at the initial application and periodic redeterminations. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing No.: 10.557 Federal Agency: US Department of Agriculture Passed-through: California Department of Public Health Award Number and Year: 22-10294 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. 2 CFR 200.318(i) Procurement records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: As a result of our procurement testing, we identified one (1) instance out of a population of one (1) where the County did not document the history of the procurement, including the rationale for method of procurement, selection of contract type, basis for contractor selection, and basis for the contract price. Cause: The County’s procurement policy and procedures do not comply with the uniform guidance requirements to obtain document the history of each procurement transaction. Effect: The County did not comply with the procurement, suspension and debarment requirements. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over procurement. We selected 100% of the procurements in the year under audit. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that the history of each procurement transaction. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Foster Care Federal Financial Assistance Listing No.: 93.658 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2024 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted two (2) out of 44 cases were incorrectly identified as federal eligible by the County. Cause: The County transitioned to the California Statewide Automated Welfare System (CalSAWS) in the fiscal year 2024. During this transition, the case was inadvertently converted to a federal case in error. Effect: The County did not comply with the eligibility requirements. Questioned Costs: Known questioned costs were $15,517. Projected questioned costs were $92,568. Context/Sampling: The condition noted above was found during our testing procedures over eligibility. A sample of 44 cases out of a population 221 were selected for testing. The sample represented $579,924 in benefits out of $2,036,487. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards reviewing cases for federal eligibility. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Foster Care Federal Financial Assistance Listing No.: 93.658 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2023/2024 Compliance Requirement: Allowable Activities and Allowed Costs Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. This includes internal controls to ensure that federal funds are used only for federally eligible cases. Condition: As a result of our allowable activities and allowed cost testing, we noted one (1) out of 60 benefit payments which was paid to an eligible participant for federal benefits. Cause: The County transitioned to the California Statewide Automated Welfare System (CalSAWS) in the fiscal year 2024. During this transition, the case was inadvertently converted to a federal case in error. Effect: The County did not comply with the allowed activities and allowable costs requirements. Questioned Costs: Known questioned costs were $1,319. Projected questioned costs were $25,151. Context/Sampling: The condition noted above was found during our testing procedures over allowable activities and allowed costs. A sample of 60 benefit payments out of a population 2,293 were selected for testing. Our sample represented benefit payments of $53,252 out of $2,036,487. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards reviewing cases for federal eligibility prior to authorizing payment of benefits. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. In one (1) out of 60 cases, we found that the County did not retain a copy of the CW2.1 to evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria:2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. We also found that the subrecipient did not reflect the expenditures of the subaward in its single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Health Care Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County does have documented policies and procedures for the evaluation of the subrecipient’s risk of noncompliance and subrecipient monitoring procedures; however, the risk assessment was performed in November 2022, which was after the agreement was in effect for the fiscal year 2023, and the review of the risk assessment was not documented until March 2023. Based on the County’s policy for monitoring of the subrecipient based on the assessed level of risk, the County was required to obtain and review quarterly reports and perform a site visit. There was no documentation supporting the receipt, review, and results of the review of the quarterly reports. There was also no evidence of the review and communication of the results of the site visit to the subrecipient. Cause: The County was unable to finalize the revised subrecipient agreement prior to fiscal year 2023, the County department adopted the policies and procedures to perform the risk assessment after the beginning of fiscal year 2023, and the subrecipient monitoring policies and procedures do not require the department to document its review and results of monitoring procedures. Effect: The County did not include all the required elements in their subaward, did not perform a risk assessment prior to the fiscal year 2023 subaward, and did not document the results of the monitoring procedures performed over the subaward. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-003. Recommendation: We recommend that the County continue to strengthen its policies and procedures over subrecipient monitoring to ensure that a risk assessment is completed prior to the start of the annual award and reviewed timely, and strengthen its policies and procedures to ensure that the results of monitoring procedures are documented and review. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Federal Financial Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a – direct award Award Number and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,125,897 $3,125,897 $3,125,897 $3,125,897 $3,125,897 Cause: Management asserted that the County’s award is not available in the FFATA portal; therefore, they are unable to submit the FFATA reports for the subrecipient of this grant. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: None reported. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-004. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Federal Financial Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted one (1) out of 60 cases were missing the notice and agreement for child, spousal and medical support (form CW2.1) for support the applicants child support cooperation. Cause: The County’s policies and procedures did not ensure that all CW2.1 forms were retained in the applicants’ file. Effect: By not obtaining and retaining the required forms and applicant files, the County increases its risk of ineligible individuals receiving benefits or incorrect benefit amounts and increases the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: The condition noted above was found during our testing procedures over eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 47,275 were selected for testing. This represented $78,812.43 of benefit payments out of $9,661,186. In one (1) out of 60 cases, we found that the County did not retain a copy of the CW2.1 to evidence the applications cooperation with the child, spousal and medical support conditions. However, we found that the related recipient/case was still eligible. Repeat Finding from Prior Year(s): Yes, prior year finding 2022-005. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to obtaining the required forms. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: Out of four quarterly (4) reports sampled, we noted three (3) instances where the review and approval of the submitted reports was not documented. The County implemented a documented review of the reports prior to submission beginning with the April 2023 quarterly report. Cause: The County’s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County’s reports on the awards were not reviewed for accuracy. Questioned Costs: None reported. Context/Sampling: We selected four (4) reports out of eight (8) required quarterly reports. We noted that all of the selected reports were accurate and submitted timely. Repeat Finding from Prior Year: Yes. See prior year finding 2022-009. Recommendation: We recommend that the County continue to strengthen its policies and procedures to ensure that the review report of all reports is performed prior to submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Financial Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300. Condition: We identified that the County’s purchasing and contracting policy does not require the verification of the debarment and suspension status of vendors prior to entering into agreements. Cause: The County is in process of updating its purchasing and contracting policy to include verifying the debarment and suspension status of vendors prior to entering into agreements through one of the permitted methods: verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract. The County’s current purchasing and contracting policy does not require verification of the vendors debarment and suspension status. Effect: Noncompliance with these requirements could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None reported. Context/Sampling: The County’s purchasing and contracting policy utilized by the department does not include verification of vendor debarment and suspension status prior to entering in the agreement. Repeat Finding from Prior Year: Yes. See prior year finding 2022-010. Recommendation: We recommend that the County implement in its policies procedures to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria:2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. We also found that the subrecipient did not reflect the expenditures of the subaward in its single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Medicaid Cluster Federal Financial Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Health Care Services Award Number and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: Per the 2023 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency’s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we identified 36 instances out of 60 sampled in which the annual redeterminations for in-home supportive services were not performed or not performed timely. In the same sample, we identified 2 instances in which the in-home supportive services benefit application (SOC295) was not retained by the County. Cause: The County’s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) program recipient applications were retained. Effect: The lack of performance of timely eligibility redetermination and by not retaining supporting documentation for applications could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program. Questioned Costs: None reported. Context/Sampling: A sample of 60 in-home supportive services recipients were selected out of 5,722. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Reported Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $2,765,946 $2,765,946 $2,765,946 $2,765,946 $2,765,946 Cause: Management asserted that the agreement had been in place for greater than 10 years and had no reason to be updated. Management has also asserted that they do not have access to submit the FFATA reports. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate, or incomplete being submitted to the federal agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-005. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Temporary Assistance for Needy Families Assistance Listing No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Number and Year: 1946001347 A7, 2021/2022 Compliance Requirement: Allowable Costs, Eligibility and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per the 2022 OMB Compliance Supplement, agencies are required to maintain eligibility records including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition: As a result of our eligibility testing, we noted the following: ? Two (2) out of 60 cases tested were missing the annual redetermination for the reevaluation of their benefits and eligibility requirements. ? 31 out of 60 cases the evidence of the review of the Income Eligibility and Verification System (IEVS) report were not documented during the applicable or annual redetermination applicable to the fiscal year. Cause: The County?s policies and procedures did not ensure that 1) timely redeterminations are performed for all program recipients, and 2) IEVS reports are reviewed for all application/redeterminations. Effect: The lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of noncompliance with the program Questioned Costs: We identified known questioned costs of $1,731. Context/Sampling: The condition noted above was found during our testing procedures over allowed costs, eligibility and special tests and provisions. A sample of 60 benefit payments out of a population 38,950 were selected for testing. This represented $42,512 of benefit payments out of $7,048,799. In two (2) out of 60 cases, we found that the County did not maintain evidence of its annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individuals are still receiving benefits. In 31 out of 60 cases, we found that the review of the IEVS was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Eligibility Type of Finding: Significant Deficiency, Instance of Noncompliance Criteria: The Consolidated Appropriations Act, 2021, for Emergency Rental Assistance Program (ERA) requires the entity to establish and document their policies and procedures for determining a household?s eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. Within those policies, the grantee is required to specify under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance, and in such cases, grantees must have in place reasonable validation or fraud-prevention procedures to prevent abuse. Condition: The County?s policy and procedures for eligibility determination did not incorporate policies and procedures specifying under what circumstances they will accept written attestations from the applicant without further documentation to determine any aspect of eligibility or the amount of assistance. Cause: The County did not formulate complete policies and procedures for the program. Effect: The County?s policies and procedures were incomplete. Questioned Costs: None identified. Context/Sampling: This instance was identified through our review of the County?s policies and procedures. Repeat Finding from Prior Year: No. Recommendation: We recommend the County revise its policies and procedures for the program. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: We noted that reports were submitted for the program did not go through a review process. Furthermore, we identified two instances in which quarterly report amounts were not accurately reported. We identified two instances in which amounts reported were inaccurate. In both instances, we found that the cumulative expenditures reported did not agreed to the underlying accounting records. In one instance, we found that the County incorrectly reported cumulative obligations and cumulative expenditures as zero. Cause: The County did not establish a review and approval process for the reports submitted for the program. Effect: The County?s reports did not go through a review process. Amounts were not accurately reported. Questioned Costs: None noted. Context/Sampling: These instances were identified through our procedures over compliance with the Uniform Guidance for reporting. A sample of 6 (2 quarterly, 4 monthly) reports out of a population of 16 (2 quarterly and 12 monthly) were selected for testing. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County strengthen its internal controls to ensure that reports are subject to review prior to submission and maintain evidence of a review and approval. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1. Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: None noted. Context/Sampling: We selected 100% of the County?s subrecipients of the program. $6,177,719 was paid to the subrecipient during the fiscal year. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. Condition: Out of 4 reports sampled, we noted four (4) instances where the review and approval of the submitted reports was not documented. Cause: The County?s internal control environment was impacted by a shortage of staff necessary to fully conduct the program. Effect: The County?s reports on the awards were not reviewed for accuracy. Questioned Costs: None noted. Context/Sampling: We selected four (4) reports out of eight (8) submitted. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over reporting. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Epidemiology and Laboratory Capacity for Infectious Diseases Assistance Listing No.: 93.323 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award Number and Year: 0187.5280 ELC CARES, COVID-19ELC48, COVID-19ELC106, 187.3408, 2021/2022 Compliance Requirement: Procurement, Suspension and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: Per 2 CFR part 200, subpart D, section 200.303, the nonfederal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award is compliance with federal statues, regulations, and the terms and conditions of the federal award. Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 Condition: Out of 7 reports procurements sampled, we noted 4 instances where there was no evidence that management performed a verification of tested covered transactions by checking the EPLS and management did not obtain a certification or added a clause or condition to the covered transaction. Cause: While aware of the requirements, the County did not have internal controls in place to ensure compliance with the procurement and suspension and debarment requirements. Effect: Noncompliance requirements for entering into contracts with vendors could result in disbursement of Federal funds to suspended or debarred parties. Questioned Costs: None noted. Context/Sampling: A nonstatistical sample of 7 out of 32 contracts were selected. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County implement policies and procedures to ensure procurement methods are properly documented, and to verify SAM registration status of potential vendors, collect certification from potential vendors, or include a clause or condition to the contract to verify that entities to which the County is awarding Federal funds is not suspended or debarred. We also recommend that management review its current vendors to ensure they are not suspended or debarred and maintain documentation of the verification procedure performed. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: WIA/WIOA Cluster Assistance Listing No.: 17.258, 17.259, 17.278 Federal Agency: US Department of Labor Passed-through: State of California Employment Development Department (EDD) Award Year and Number: AA011039, AA111039, AA211039, AA311039, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Instances of Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: We identified one (1) instance in which a required financial report was not submitted, and one (1) instance in which amounts were incomplete/inaccurately reported. Cause: The County did not have procedures in place over these reports to ensure that all required financial reports were submitted and that financial reports were complete and accurate prior to submission. Effect: By not having procedures in place to ensure that 1) all required reports are submitted and 2) reports are complete and accurately prepared, this increases the County?s risk of noncompliance with the program. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context/Sampling: The condition noted above was found during our testing procedures over reporting. A sample of 14 out of 65 reports were selected. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County review its policies and procedures with regards to the preparation and submission of reports. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Section 8 Housing Choice Vouchers CFDA No.: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Year: 2020-2021 Compliance Requirement: Other Type of Finding: Significant Deficiency Grant Award Number: CA131 Criteria: Title 2 Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires the County of Solano, California (County) to prepare a Schedule of Expenditures of Federal Awards (SEFA) showing both total federal expenditures and payments to subrecipients for the year. Condition Found: The Catalog of Domestic Financial Assistance (CFDA) or Federal Financial Assistance Number was misreported on the SEFA. Questioned Costs: No known questioned costs identified. Context: We identified that the Section 8 Housing Choice Voucher Program?s expenditures were incorrectly reported on the SEFA under the Section 8 Project-Based Cluster. Effect: The program expenditures were misidentified on the SEFA. Cause: The County?s internal controls over the preparation of the SEFA did not ensure that the Section 8 Housing Choice Vouchers program was properly identified. Recommendation: We recommend that the County strengthen its procedures over the preparation of the SEFA to ensure that programs are properly identified, and expenditures are properly recognized in accordance with the Uniform Guidance. Views of Responsible Officials Management agrees with the finding. See separate corrective action plan.

Program: COVID-19 Coronavirus Relief Fund CFDA No.: 21.019 Federal Agency: U.S. Department of the Treasury Passed-through: California Department of the Treasury Award Year: 2020-2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness, Material Instances of Noncompliance Grant Award Number: 20-1892-0-1-806 Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County of Solano, California or ?County?) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition Found: In 3 out of 4 subrecipient awards selected for review, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County department did not have documented policies or procedures for the evaluation of each subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County department did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County department did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 4 out of 4 subrecipient awards selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In these same instances, a documented review of whether the subrecipient was subject to a single audit was also not performed. All 4 of the subrecipient awards selected were administered by department of the County Administrator. In 2 out of the 4 subrecipient awards selected, we found that the County identified questioned costs as a result of their monitoring activities. However, these monitoring activities were performed subsequent to the completion of the contract. The County has not yet recovered the questioned costs from the subrecipients. Questioned Costs: We identified known questioned costs of $325,008. These questioned costs were identified by the County through their monitoring activities. Context/Sampling We selected 100% of the County?s subrecipients of the program. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Coronavirus Relief Fund CFDA No.: 21.019 Federal Agency: U.S. Department of the Treasury Passed-through: California Department of the Treasury Award Year: 2020-2021 Compliance Requirement: Other Type of Finding: Significant Deficiency, Instance of Noncompliance Grant Award Number: 20-1892-0-1-806 Criteria: 2 CFR 200.303(a) requires that 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 statutes, regulations, and the terms and conditions of the Federal award. An element of effective internal controls includes ensuring that an individual is not in a position to review or approve transactions in which they have a financial interest in (a conflict of interest). Condition Found: We identified an instance in which a County employee was assigned as the contract administrator to a subrecipient contract with an organization in which the employee was concurrently a member the Board of Directors. The contract administrator was responsible for the substantive review of the contract and responsible for monitoring of the subrecipients compliance with the contract provisions. Questioned Costs: We identified known questioned costs of $67,635. These questioned costs are included in the questioned costs identified in Finding 2021-002. These questioned costs were identified by the County through their monitoring activities. Context/Sampling This instance was identified through our procedures performed to gain an understanding of the County?s internal control over compliance with the Uniform Guidance for subrecipients. Effect: The County had related party transactions that were not identified, and monitoring procedures were not put into place to mitigate a conflict of interest. Cause: The County?s internal controls were not designed effectively to prevent an individual from reviewing a subrecipient contract in which they had a related party relationship. Recommendation: We recommend that the County strengthen internal controls to identify and prevent County employees from overseeing contracts in which the employees? have a financial interest in. We also recommend that the County establish policies and procedures to identify and track related party transactions. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Section 8 Housing Choice Vouchers CFDA No.: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Year: 2020/2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness, Material Noncompliance Grant Award Number: CA131 Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition Found: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Questioned Costs: No known questioned costs identified. Context/Sampling We selected 100% of the County?s subrecipients of the program. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Program: Section 8 Housing Choice Vouchers CFDA No.: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Year: 2020/2021 Compliance Requirement: Reporting Type of Finding: Material Weakness, Material Noncompliance Grant Award Number: CA131 Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 170 establishes requirements for recipients? reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: Transactions Tested Subaward Not Report Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements 1 1 1 1 1 Dollar Amount of Tested Transactions Subaward Not Report Report Not Timely Subaward Amount Incorrect Subaward Missing Key Elements $3,010,491 $3,010,491 $3,010,491 $3,010,491 $3,010,491 Cause: Management asserted that the agreement had been in place for greater than 10 years and had no reason to be updated. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted to the federal agency. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: We tested 100% of all subrecipients. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that management strengthen their processes and procedures related to the submission of the required FFATA reports to ensure compliance with the program requirements. We also recommend that management establish documented review of the required FFATA reports by an individual other than the preparer prior to submission and retain record of the review and submission. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Finding 2019-001 Program: WIOA Cluster CFDA No.: 17.258, 17.259, 17.278 Federal Agency: U.S. Department of Labor Passed-through: California Employment Development Department Award Year: 2018-2019 Compliance Requirement: Matching, Earmarking, and Level of Effort Criteria: Per the 2019 OMB Compliance Supplement, not less than 20 percent of Youth Activity funds allocated to the local area, except for the local area expenditures for administration, must be used to provide paid and unpaid work experiences (Section 129(c)(4)), WIOA, 128 Stat. 1510). Condition Found: Instance of Non-Compliance ? The Workforce Development Board (WDB) of the County of Solano (County) did not spend at least 20 percent of Youth Activity funds allocated to the local area under Grant Agreement #K8106686 on paid and unpaid work experiences. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context: The condition noted above was identified during our procedures over Matching, Earmarking and Level of Effort. We found that the County had not spent the minimum 20% of Youth Activity funds allocated under the grant agreement on paid and unpaid work experiences. Effect: The County did not comply with the 20 percent requirement. Cause: The County?s procedures and internal controls did not ensure compliance with the Matching, Earmarking, and Level of Effort requirements of the program. Recommendation: We recommend that the County strengthen its existing policies and procedures to ensure compliance with the program?s requirements are monitored and maintained in accordance with the grant award and program.

Finding 2019-002 Program: TANF Cluster ? Temporary Assistance for Needy Families Program CFDA No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Year: 2018-2019 Compliance Requirement: Eligibility Criteria: Per the 2019 OMB Compliance Supplement, agencies are required to maintain eligibility records, including documents to support the agency?s eligibility determination and information about each individual and benefits paid to or on behalf of the individual. In addition, it is required that eligibility determinations and redeterminations, including obtaining any required documentation and verifications, are performed annually to determine if individuals are eligible in accordance with the compliance requirements of the program. Condition Found: Significant Deficiency, Instances of Noncompliance ? As a result of our eligibility testing, we noted the following: ? 1 out of 60 cases where the eligibility re-determinations were not performed timely, but the individual is still receiving benefits. ? 6 out of 60 cases in which evidence of the review of the IEVS report was not documented during the applicable application or annual re-determination applicable to the fiscal year. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context: The condition noted above was found during our testing procedures over eligibility. In 1 out of 60 cases, we found that County did not perform the annual re-determination for the re-evaluation of their benefits and eligibility requirements. The individual is still receiving CalWORKs benefits. In 6 out of 60 cases, we found that the review of the Income Eligibility and Verification System (IEVS) was not documented during the application or annual re-determination applicable to the fiscal year. However, we found that the related recipients/cases were eligible. Effect: Lack of performance of timely eligibility redetermination and supporting documentation for eligibility determinations could result in ineligible individuals receiving benefits and increase the risk of non-compliance with the program. Cause: The County?s policies and procedures did not ensure that 1) timely re-determination are performed for all program recipients, and 2) IEVS reports are reviewed for all application/re-determinations. Recommendation: We recommend that the County strengthen its current policies and procedures with regards to eligibility redeterminations, required documentation, and maintenance of participant file and ensure that such policies and procedures are formally documented.

Finding 2019-003 Program: TANF Cluster ? Temporary Assistance for Needy Families Program CFDA No.: 93.558 Federal Agency: U.S. Department of Health and Human Services Passed-through: California Department of Social Services Award Year: 2018-2019 Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.331(b) establishes the requirement that the pass-through entity (the County Health and Social Services department) must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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 Found: Significant Deficiency, Instance of Noncompliance ? We found that the County did not have documented policies or procedures for the evaluation of each subrecipient?s risk of noncompliance with program requirements for the fiscal year 2018/19 and found that the County did not adequately perform a documented risk assessment for three (3) out of three (3) sampled subawards effective in the fiscal year ended June 30, 2019. We also found that the County?s subrecipient performance monitoring procedures did not include records to evidence the communication of the results of the performance monitoring activities to the responsible individual(s) of the subrecipient. Questioned Costs: We identified no questioned costs in our tests of compliance with this requirement. Context: The condition noted above was found during our testing procedures over subrecipient monitoring. The County did not have documented policies and procedures to assess the risk of subrecipient noncompliance with Federal statutes, regulations, and terms and conditions of subawards. However, the County asserted that a risk assessment was performed, but was not formally documented. The County subsequently documented their risk assessment policy and monitoring procedures and documented their risk assessment of the program subrecipients for the fiscal year 2018/19. We found that the County?s monitoring activities that were conducted during the year to be in accordance with the subsequently adopted risk assessments and monitoring activities policies. As a result of our testing over the County?s performance monitoring procedures, we found that the County?s records included periodic performance reports in accordance with their risk assessment and monitoring procedures. However, we found that the records did not include evidence of the communication of the results of the performance monitoring procedures to the subrecipient. Management indicated that the results were communicated to the subrecipients, but the communication was not formally documented. Effect: As a result of not documenting the performance of the County?s assessment of the risk of the subrecipient?s noncompliance with program requirements under 2 CFR 200.331(b), the County did not fully comply with the program requirements, and as a result, there is a risk that the subrecipient?s noncompliance with program requirements is not identified and corrected timely. Additionally, as a result of not retaining records to evidence the results of the performance monitoring procedures, this increases the risk of noncompliance with the requirements under 2 CFR200.331(d). Cause: The County did not have documented risk assessment and monitoring procedures for subrecipients of the program for the fiscal year 2018/19. As stated above, management asserted that the risk assessment and monitoring activities were conducted but were not formally documented. The County?s monitoring procedures for performance monitoring also does not include procedures for documenting and communicating the results of monitoring activities to the program subrecipients. Recommendation: We recommend that the County establish policies and procedures to ensure that risk assessments are conducted for all subrecipient awards as required under 2 CFR 200.331(b), and 2 CFR 200.331(d) through 2 CFR 200.331(f), and we recommend that the County establish procedures to communicate the results of performance monitoring procedures to program subrecipients.

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