County of Los AngelesLocal Government

Reference Number: 2025-002 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2024-25 Name of Department with Finding: Department of Consumer and Business Affairs Name of Departments with No Findings: Chief Executive Office Aging and Disabilities Executive Office of the Board of Supervisors Department of Public Health Department of Economic Opportunity Internal Services Justice Care and Opportunities Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(c)(e)(f), all pass-through entities must: (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. (f) Depending upon the pass-through entity's assessment of the risk posed by the subrecipient (as described in paragraph (c) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing site visits to review the subrecipient's program operations; and (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. Condition During our audit of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, we selected twenty one (21) subrecipients with active contracts with the County during FY 2024-25. We noted that the Department of Consumer and Business Affairs (DCBA) did not perform subrecipient monitoring for four (4) contracts administered by the department, of which one (1) contract did not have a risk assessment performed during FY 2024-25. In addition, we selected two (2) subrecipients with total expenditures of $19,217,030 that were subjected to subrecipient monitoring compliance requirements; however, it was determined that the selected subrecipients were vendors and inadvertently included in the subrecipient population. In the SEFA, the passed through to subrecipients column for this grant was reduced by $19,217,030 to reflect this correction. This is a repeat finding of 2024-002 as it relates to the subrecipient monitoring portion of the Condition. Cause Due to limited resources, the department needed more time to complete risk assessment, monitor the CSLFRF subrecipients and document the reviews in accordance with subrecipient monitoring requirements. Effect Failure to document risk assessment and monitoring results is noncompliance with the subrecipient monitoring requirements 2 CFR § 200.332 (c)(e)(f). Questioned Costs Questioned costs were not determinable. Context Of the twenty one (21) subrecipients selected for testing, which totaled $192,086,158, from a population of ninety-seven (97) subrecipients with expenditures totaling $282,469,393, the department did not perform an annual risk assessment for one (1) subrecipient and they did not have documentary evidence supporting the monitoring of four (4) subrecipients with expenditures totaling $5,917,341. However, the department retained copies of the subrecipients’ single audit reports. The misclassification of vendors was corrected by removing them from the subrecipient expenditures, which decreased subrecipient expenditures from $301,686,423 to $282,469,393. DCBA had 7 subrecipients with total expenditures of $99,128,273 out of the total of 97 subrecipients with total expenditures of $282,469,393. The sample was not a statistically valid sample. Recommendation We recommend the County perform risk assessments and monitor the activities of its subrecipients as necessary to ensure that subawards are used for authorized purposes and maintain appropriate records for monitoring subrecipients in accordance with subrecipient monitoring requirements set forth in 2 CFR § 200.332 (c)(e)(f).

Reference Number: 2025-003 Federal Program Title: Immunization Cooperative Agreements Federal Assistance Listing Number: 93.268 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Public Health (CDPH) Federal Award Number and Year: 22-11039 July 1, 2022 – June 30, 2027 Name of Department: Department of Public Health, Immunization Program Category of Finding: Reporting and Special Tests and Provisions Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria In accordance with the Scope of Work (SOW) of the grant agreement and the related statutes under the California Health & Safety Code sections: • 120130 requires the Local Health Officer to properly report to CDPH those diseases listed as reportable, which include vaccine-preventable diseases. • 120175 requires the Local Health Officer to take measures as may be necessary to prevent the spread or occurrence of additional cases of reportable diseases (which includes reportable vaccine-preventable diseases). • 120350 requires Local Health Officers to organize and maintain a program to make available the immunizations required for admittance to childcare facilities and schools. The County of Los Angeles Department of Public Health (DPH) is responsible for monitoring each program component: 1) Vaccine Accountability and Management; 2) Access to and Utilization of Quality Immunization Services; 3) California Immunization Registry (CAIR); 4) Perinatal Hepatitis B Prevention; 5) Education, Information, Training, and Partnerships; 6) Prevention, Surveillance and Control of Vaccine Preventable Disease (VPD); 7) Childcare and School Immunization Entry Requirements; 8) Influenza; and 9) COVID-19 Vaccination. Under each of these component areas, there are objectives and required activities to be performed to meet the objectives. On a semi-annual basis, the Los Angeles County Vaccine Preventable Disease Control Program (VPDCP) will report to CDPH on the progress for the pertinent objectives and activities, as delineated in the grant SOW. Condition During our audit of DPH Immunization Cooperative Agreement program’s Access to and Utilization of Quality Immunization Services component, we noted that VPDCP was unable to provide the supporting log of Medi-Cal members’ access to immunization problems resolved at the local level or reported to CDPH. Cause The log documenting Medi-Cal members’ access to immunization problems could not be located. VPDCP management indicated that, due to staff turnover, the file may have been saved on an individual employee’s local drive rather than in a shared directory accessible to the program. Effect The absence of required documentation prevents validation of the reported progress and undermines assurance that the objective was achieved as stated. Questioned Cost Questioned costs were not identified. Context In the Biannual Progress Report for January 1, 2025, to June 30, 2025, VPDCP reported that Component Area 2, Goal 2.1b had been met. The performance measure for this activity requires VPDCP to maintain a log of access problems resolved at the local level or reported to CDPH. VPDCP was unable to provide this log, preventing confirmation that the activity was completed as reported. Recommendation VPDCP should require all required program documentation be stored in a centralized shared location and implement oversight procedures, including transition checklists and periodic reviews, to ensure documentation is consistently maintained and accessible. These actions will help ensure that required evidence is consistently retained and available to support reported progress to the CDPH.

Reference Number: 2024-001 Federal Program Title: Public Health Emergency Preparedness Federal Assistance Listing Number: 93.069 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU90TP922022-05-00; Fiscal Year 2023-24 Name of Department: Department of Public Health Category of Finding: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance; Material Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 180.200 a covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR § 180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR § 180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR § 180.985, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Department of Public Health (DPH) compliance with the procurement and suspension and debarment requirements for the Public Health Emergency Preparedness Program, we noted that for eleven (11) contracts, DPH did not provide documentation to demonstrate DPH verified that the vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction. Based on a subsequent review of the SAM exclusions, the vendors in question are not suspended or debarred. This is a repeat finding of 2023-008.   Cause DPH did not provide procurement and suspension and debarment documentation due to staff shortages and increased workload. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR § 180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context For the thirty-eight (38) contracts selected for testing, which totaled $84,787 from a population of 160 contracts with expenditures totaling $2,616,122, DPH did not provide the suspension and debarment documentation for eleven (11) contracts with expenditures totaling $10,272. The sample was not a statistically valid sample. Recommendation We recommend that DPH either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.

Reference Number: 2024-002 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2023-24 Name of Department: County Executive Office Department of Aging Department of Arts and Culture Department of Economic Opportunity Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance; Material Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(e), all pass-through entities (PTE) must: Monitor the activities of the subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notification from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue management decision for audit findings pertaining to only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Condition During our audit of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, we selected fifteen (15) subrecipients with active contracts with the County during FY 2023-24. We noted for seven (7) contracts administered by the Departments of Aging, Arts and Culture, and Economic Opportunity, the departments did not perform subrecipient monitoring related to the CSLFRF program during FY 2023-24. This is a repeat finding of 2023-009. Cause Due to the urgency to implement the CSLFRF program, the departments needed more time to enter into contracts with independent CPA firms to monitor the CSLFRF subrecipients and document the reviews in accordance with subrecipient monitoring requirements. Effect Failure to document monitoring results in noncompliance with the subrecipient monitoring requirements 2 CFR § 200.332(e). Questioned Costs Questioned costs were not determinable. Context Of the fifteen (15) subrecipients selected for testing, which totaled $20,981,306, from a population of 76 subrecipients with expenditures totaling $101,950,949, the departments did not perform subrecipient monitoring for seven (7) subrecipients with expenditures totaling $19,118,116. The sample was not a statistically valid sample. Recommendation We recommend the County monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and maintain sufficient records of monitoring subrecipients in accordance with subrecipient monitoring requirements.

Reference Number: 2023-001 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-02-04; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Schedule of Expenditure of Federal Awards Type of Finding: Significant Deficiency in Internal Control Over Financial Reporting Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.510 the non-Federal entity must prepare the schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee non-Federal entity's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. 2 CFR § 200.502 states: The determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs. Generally, the activity pertains to events that require the non-Federal entity to comply with Federal statutes, regulations, and the terms and conditions of Federal awards, such as: expenditure/expense transactions associated with awards including grants, cost-reimbursement contracts under the FAR, compacts with Indian Tribes, cooperative agreements, and direct appropriations; the disbursement of funds to subrecipients; the use of loan proceeds under loan and loan guarantee programs; the receipt of property; the receipt of surplus property; the receipt or use of program income; the distribution or use of food commodities; the disbursement of amounts entitling the non-Federal entity to an interest subsidy; and the period when insurance is in force. Condition During our audit of the Department of Public Health’s (DPH) Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH under reported expenditures in the SEFA for fiscal year ended June 30, 2022 by $27.5 million. The County disclosed the prior year expenditures not previously reported in note 9 to the SEFA. Cause The program misinterpreted guidance provided by the Office of the Auditor-Controller on identifying expenditures to include in the SEFA, and did not include accruals recorded in the accounting system for services incurred but not paid as of June 30, 2022. Effect Failure to accurately identify and report Federal expenditures in the SEFA could affect the major program determination and the programs selected for audit. Questioned Costs Questioned costs were not identified. Context The FY 2021-22 SEFA underreported $27.5 million of expenditures, constituting 4.5 percent of the ELC program’s reported total expenditures of $607.4 million, or 4.3 percent of the ELC program’s actual total expenditures of $634.9 million. The County disclosed the prior year expenditures not previously reported in note 9 of the notes to the SEFA. The under reporting of expenditures in the SEFA did not affect the prior year’s major program determination and programs selected for audit. Recommendation We recommend that the DPH strengthen its processes for identifying and reporting Federal expenditures in the SEFA to ensure all services incurred but not paid during the applicable fiscal year are appropriately included in the SEFA.

Reference Number: 2023-002 Federal Program Title: Maternal and Child Health Services Block Grant to the States Federal Assistance Listing Number: 93.994 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Health Care Services/Public Health Institute Federal Award Number and Year: 202219; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Schedule of Expenditure of Federal Awards Type of Finding: Significant Deficiency in Internal Control Over Financial Reporting Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.510 the non-Federal entity must prepare the schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee non-Federal entity's financial statements which must include the total Federal awards expended as determined in accordance with § 200.502. At a minimum, the schedule must provide total Federal awards expended for each individual Federal program and the Assistance Listings Number (ALN). Condition During our audit of the DPH’s Maternal and Child Health Services Block Grant to the States (MCH) program, we noted that DPH incorrectly reported expenditures for the MCH Program in the SEFA. $2,163,020 in expenditures for ALN 93.778 Medicaid Assistance Program, were reported as MCH Program expenditures under ALN 93.994. The SEFA was corrected to properly report the expenditures under both ALNs. Cause DPH used funds from ALN 93.778 Medicaid Assistance Program, as matching funds for the MCH Program, as allowed by the MCH Program. While DPH tracked the expenditures for the two ALNs separately, it reported all of the expenditures in the SEFA under the MCH Program. Effect Failure to accurately identify and report Federal expenditures in the SEFA could affect the major program determination and the programs selected for audit and the timely completion of the Single Audit. The MCH program was selected as a Type B program and audited for FY 2022-23. Upon correcting the error identified, an additional Type B program was required to be selected for audit, as MCH fell below the Type B program threshold for FY 2022-23 and did not need to be considered in the County’s risk assessment. Questioned Costs Questioned costs were not identified. Context The MCH Program originally reported total expenditures of $3,361,264 in FY 2022-23 for two different federal programs: ALN 93.994 for $1,198,244 and ALN 93.778 for $2,163,020. DPH reported the expenditures as $3,361,264 for ALN 93.994 and $0 for ALN 93.778. The SEFA was corrected to appropriately report the expenditures in ALN 93.994 and ALN 93.778. Recommendation We recommend that the DPH strengthen its processes for identifying and reporting Federal expenditures in the SEFA to ensure expenditures are reported under the correct federal program ALN.

Reference Number: 2023-003 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-02-06; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Reporting Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 170 – Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 – Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. A subaward may be provided through any legal agreement. 2 CFR § 200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the Department of Public Health’s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA report for one (1) subaward after the due date. See the Notes to the SEFA for chart/table. This is a repeat finding of 2022-009. Cause DPH used the date of a notice to the subrecipient, December 16, 2022, for FFATA reporting; and not the date of the subaward agreement’s amendment, October 5, 2022. The notice is not a legal agreement. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Five (5) subawards requiring the submission of a FFATA report were selected from a total population of seven (7) subawards, and a FFATA report was not submitted timely for one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH develop and document a process to identify, track and report all subaward agreements and modifications executed throughout the fiscal year and subject to FFATA reporting requirements.

Reference Number: 2023-004 Federal Program Title: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Federal Assistance Listing Number: 93.354 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU90TP922183-01-03; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Reporting Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 170 – Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 – Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR § 200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the DPH’s compliance with the reporting requirement for the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response (PHER) program, we noted that DPH submitted the FFATA reports for two (2) subawards after the due date. See the Notes to the SEFA for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Two (2) subawards requiring the submission of a FFATA report were selected for testing from a total population of three (3) subrecipient awards, and FFATA reports were not submitted timely for two (2) subawards. The sample was not a statistically valid sample. Recommendation We recommend that the DPH develop and document a process to identify, track and report all subaward agreements and modifications executed throughout the fiscal year and subject to FFATA reporting requirements.

Reference Number: 2023-005 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 6 NU62PS924569-05-03; 6 NU62PS924569-05-04; 6 NU62PS924569-05-05; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Reporting Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 170 – Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 – Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR § 200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the DPH’s compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH submitted the FFATA reports for seven (7) subawards after the due date. See the Notes to the SEFA for chart/table. This is a repeat finding of 2022-010. Cause The program reported subaward agreements and modifications in December 2022 and at fiscal year-end in June 2023, rather than 30 days after when the subaward agreements or modifications occurred. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Ten (10) subawards requiring the submission of a FFATA report were selected for testing from a total population of 38 subrecipient awards, and FFATA reports were not submitted timely for seven (7) subawards. The sample was not a statistically valid sample. Recommendation We recommend that the DPH develop and document a process to identify, track and report all subaward agreements and modifications executed throughout the fiscal year and subject to FFATA reporting requirements.

Reference Number: 2023-006 Federal Program Title: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Federal Assistance Listing Number: 93.354 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU90TP922183-01-03; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria Procurement In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.318: (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR § 200.319 states: (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and § 200.320. 2 CFR § 200.320 states: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Suspension and Debarment In addition, in accordance with 2 CFR § 180.200 a covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR § 180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR § 180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR § 180.985, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Department of Public Health (DPH) compliance with the procurement and suspension and debarment requirements for the Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Program, we noted that for one (1) contract, DPH did not provide documentation related to the history of the procurement. Therefore, we were unable to determine whether DPH complied with the procurement requirements related to the method of procurement, competition, and the basis for the contract price. In addition, for the same one (1) contract, DPH did not provide documentation to demonstrate DPH verified that the vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. Cause The Office of the County Counsel stated the contract was privileged from disclosure under attorney-client privilege and did not provide the contract or procurement related documentation. In addition, County Counsel stated the contract did not contain an explicit debarment provision and did not provide documentation that Sam.gov was reviewed or a certification from the vendor. Effect Not providing sufficient documentation to auditors to demonstrate compliance with federal compliance results in an audit scope limitation. Failure to document verification of suspension and debarment results in noncompliance with 2 CFR § 180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context For the six (6) contracts selected for testing, which totaled $37,256,347 from a population of eight (8) contracts with expenditures totaling $37,874,851, DPH did not provide procurement and suspension and debarment documentation for one (1) contract with expenditures totaling $1,499,482. The sample was not a statistically valid sample. Recommendation We recommend County departments discuss and document sensitive legal matters funded by federal funds with respective grantors to obtain guidance and direction on addressing audit requests. In addition, we recommend that DPH ensure sufficient documentation is maintained and available to demonstrate compliance with suspension or debarment. Acceptable items to confirm that vendors and subrecipients are not suspended or debarred are: 1) include a contract clause or condition to the covered transaction with that contractor, 2) search SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from the contractor.

Reference Number: 2023-007 Federal Program Title: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Federal Assistance Listing Number: 93.391 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH75OT000002-01-03; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 180.200, a covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR § 180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR § 180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR § 180.985, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Department of Public Health (DPH) compliance with suspension and debarment requirements for the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Program, we noted that for one (1) contract, DPH did not provide documentation to demonstrate DPH verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. Cause DPH was unable to locate documentation that verification of suspension or debarment occurred prior to contract execution. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR § 180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the three (3) contracts selected for testing, which totaled $1,810,023 from a population of twelve (12) contracts with expenditures totaling $2,278,647, there was one (1) contract with expenditures totaling $7,100 without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. This was not a statistically valid sample. Recommendation We recommend that DPH either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.

Reference Number: 2023-008 Federal Program Title: Public Health Emergency Preparedness Federal Assistance Listing Number: 93.069 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU90TP922022-04-01; Fiscal Year 2022-23 Name of Department: Department of Public Health Category of Finding: Procurement and Suspension and Debarment Type of Finding: Material Weakness in Internal Control Over Compliance; Material Noncompliance Criteria Procurement In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.318: (j) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR § 200.319 states: (b) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and § 200.320. 2 CFR § 200.320 states: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Suspension and Debarment In addition, in accordance with 2 CFR § 180.200 a covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR § 180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR § 180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR § 180.985, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Department of Public Health (DPH) compliance with the procurement and suspension and debarment requirements for the Public Health Emergency Preparedness Program, we noted the following: • For twenty-one (21) contracts, DPH did not provide documentation related to the history of the procurement. Therefore, we were unable to determine whether DPH complied with the procurement requirements related to the method of procurement, competition, and the basis for the contract price. • For two (2) contracts, DPH did not provide documentation of the justification and approval of sole source. Therefore, we were unable to determine whether the procurement method used was appropriate and whether limiting competition was justified. • For three (3) contracts, DPH did not provide documentation to demonstrate DPH verified that the vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction. Based on a subsequent review of the SAM exclusions, the vendors are not suspended or debarred. Cause DPH did not provide procurement and suspension and debarment documentation due to staff shortages and increased workload. For suspension and debarment, for two of the three contracts, DPH provided copies of the verification from Sam.gov, however, the documents did not have dates indicating the verification occurred prior to contract execution. Effect Failure to document the history of procurements results in noncompliance with the procurement requirements with 2 CFR §§ 200.317, 200.318, 200.319 and 200.320. Failure to document verification of suspension and debarment results in noncompliance with 2 CFR § 180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context For the twenty-seven (27) contracts selected for testing, which totaled $1,942,586 from a population of 178 contracts with expenditures totaling $2,132,936, DPH did not provide the necessary documentation for twenty-three (23) contracts with expenditures totaling $1,273,569 and suspension and debarment documentation for three (3) contracts with expenditures totaling $124,809. The sample was not a statistically valid sample. Recommendation We recommend that DPH maintain sufficient records to support vendor selection in accordance with procurement requirements. In additional, we recommend that DPH either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.

Reference Number: 2023-009 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2022-23 Name of Department: County Executive Office Internal Services Department Department of Consumer Business Affairs Department of Aging Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Condition During our audit of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, we selected twenty-three (23) subrecipients with active contracts with the County during FY 2022-23. • One (1) contract administered by the Internal Services Department (ISD) did not include one or more of the required elements defined in 2 CFR § 200.332 (a)(1) in the subrecipients’ agreements. • One (1) contract administered by the Department of Consumer Affairs (DCBA) did not include one or more of the required elements defined in 2 CFR § 200.332(a)(1) in the subrecipients’ agreements. • For four (4) contracts administered by the Aging Department (AD), the AD did not perform subrecipient monitoring related to the CSLFRF program during FY 2022-23. Cause Due to the urgency to implement the CSLFRF program, the Notice of Federal Subaward Information was not completed and provided to the subrecipient for two (2) contracts. The AD was not aware of the requirement to conduct subrecipient monitoring related to the CSLFR program and did not perform subrecipient monitoring of four (4) contracts. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Failure to document monitoring results in noncompliance with the subrecipient monitoring requirements 2 CFR § 200.332. Questioned Costs Questioned costs were not determinable. Context Of the twenty-three (23) subrecipients selected for testing, which totaled $71,323,434, from a population of 124 subrecipients with expenditures totaling $90,592,053: • The departments did not communicate all of the required subaward data elements for two (2) subrecipients with expenditures totaling $7,305,087. • The AD did not perform subrecipient monitoring for four (4) subrecipients with expenditures totaling $8,542,012. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Remind departments that the Notice of Federal Subaward Information is a required attachment for all subrecipient agreements. In addition, subaward contract templates should be reviewed and revised to include placeholders for required information 2 CFR § 200.332(a)(1). 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR § 200.332(a)(1). 3. Maintain sufficient records of monitoring subrecipients in accordance with subrecipient monitoring requirements.

Reference Number: 2023-010 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2022-23 Name of Department: County Executive Office Department of Public Health Category of Finding: Period of Performance Type of Finding: Material Weakness in Internal Control Over Compliance; Instance of Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.1, period of performance is the total estimated time interval between the start of an initial Federal award and the planned end date, which may include one or more funded portions, or budget periods. Identification of the period of performance in the Federal award per § 200.211(b)(5) does not commit the awarding agency to fund the award beyond the currently approved budget period. Per 2 CFR § 200.403 in order for costs to be allowable under Federal awards (h) cost must be incurred during the approved budget period. Per 2 CFR § 200.1, the budget period is the time interval from the start date of a funded portion of an award to the end date of that funded portion during which recipients are authorized to expend the funds awarded. Per 31 CFR § 35.5, a recipient may only use Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) for the purposes enumerated in § 35.6 (b) through (f) to cover costs incurred during the period beginning March 3, 2021, and ending December 31, 2024. Condition During our audit of the CSLFRF program, we selected twenty-five (25) employees with payroll expenditures included in the County’s CSLFRF claims during FY 2022-23, and the expenditures for two employees were incurred before March 3, 2021. Cause DPH made adjustments to employee expenditure codes to improve the capture and claiming of eligible costs in October 2022; however, certain transactions were erroneously captured from May 2020 and February 2021, which is outside the period of performance. Effect Submitting claims with costs incurred or obligated prior to the period of performance start date of March 3, 2021, results in unallowable costs and noncompliance with the period of performance requirements 31 CFR 35.5. Questioned Costs Known questioned costs were $4,703. Context Of the twenty-five (25) employees selected for testing, which totaled $59,861, from a population of more than 250 employees in five departments with expenditures totaling $43,302,346, expenditures were included for two employees totaling $4,703 that were incurred before the period of performance began March 3, 2021. The sample was not a statistically valid sample. Recommendation We recommend the County verify the date worked for all employees included in the CSLFRF claims was incurred or obligated on or after March 3, 2021.

Reference Number: 2022-001 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (2 CFR) ?200.318: (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. 2 CFR ?200.319 states: (a) All procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and ? 200.320. 2 CFR ?200.320 states: The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition During our audit of the Department of Health Services? (DHS) compliance with the procurement requirement for the National Bioterrorism Hospital Preparedness Program, we noted that for one (1) contract, DHS did not provide documentation related to the history of the procurement. Therefore, we were unable to determine whether DHS complied with the procurement requirements related to the method of procurement, competition, and the basis for the contract price. Cause The Director of the DHS, or designee, had delegated authority from the County Board of Supervisors to select, negotiate, and execute agreements with a maximum contract obligation not to exceed $500,000 annually per agreement, per award term. However, DHS was still required to follow the County?s procurement policies. Effect Failure to document the history of procurements results in noncompliance with the procurement requirements with 2 CFR 200.317, 200.318, 200.319 and 200.320. Questioned Costs Questioned costs were not identified. Context For the four (4) contracts selected for testing, which totaled $478,418 from a population of eleven (11) contracts with expenditures totaling $594,798, DHS did not provide documentation of the history of procurement for one (1) contract. The sample was not a statistically valid sample. Recommendation We recommend that DHS maintain records sufficient to detail the history of procurement and to ensure compliance with procurement requirements.

Reference Number: 2022-002 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 U3REP190604-03-00; Fiscal Year 2021-22 Name of Department: Department of Health Services Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the Department of Health Services? (DHS) compliance with the reporting requirement for the National Bioterrorism Hospital Preparedness Program, we noted that DHS was not able to demonstrate it submitted the required FFAFTA reports timely for seventeen (17) of its subawards. Furthermore, DHS did not submit a FFAFTA report for one (1) of its subaward. See Schedule of Findings and Questioned Costs for chart/table. Cause DHS was unable to access the submittal history for the reports because the previous employee responsible for FFATA reporting was no longer a DHS employee. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Eighteen (18) subawards requiring the submission of a FFATA report were selected from a total population of seventy eight (78) subawards. For seventeen (17) subawards, we were unable to determine whether the reports were submitted timely; and one (1) subaward was not reported. The sample was not a statistically valid sample. Recommendation We recommend that the DHS strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.

Reference Number: 2022-003 Federal Program Title: National Organizations of State and Local Officials Federal Assistance Listing Number: 93.011 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 4 U3SHS42183-01-02; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the National Organizations of State and Local Officials program, we noted that DPH was not able to demonstrate it submitted the required FFAFTA report timely for one (1) of its subrecipients. See Schedule of Findings and Questioned Costs for chart/table. Cause The non-adherence of the FFATA requirement was an oversight by Providing Education, Engagement, Resources and Services (PEERS) project staff. When this issue was identified in 2022, PEERS project staff ensured that contract information was submitted in May 2022. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of one (1) subrecipient award, and we were unable to determine if the FFATA report was submitted timely. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are submitted by the defined due date and retain documentation evidencing submission of the report.

Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).

Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.

Reference Number: 2022-006 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: ER-30X0 (002); ER-30X0 (007); Fiscal Year 2021-22 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our audit of the Highway Planning and Construction program, we noted that the Department of Public Works (DPW) was not able to provide documentation to demonstrate DPW verified that a vendor was not suspended or debarred from participating in federally funded contracts prior to entering into a covered transaction for three (3) of the twelve (12) vendors selected for testing. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. This is a repeat finding of 2021-001. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twelve (12) vendors with eighteen (18) contracts selected for testing, which totaled $15,433,004 from a population of $16,732,597 and seventy one (71) contracts, there were three (3) contracts without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. The three contracts were executed in FY 2011-12, FY 2012-13 and FY 2016-17, respectively; and were included in the FY 2021-22 SEFA due to DPW receiving additional federal funds in FY 2021-22 to cover prior year expenditures. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.

Reference Number: 2022-007 Federal Program Title: Guardianship Assistance Federal Assistance Listing: 93.090 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No.16/17-69, 14/15-40, 11/12-18; Fiscal Year 2021-22 Name of Department: Department of Children and Family Services Category of Finding: Eligibility Criteria The compliance criteria pertaining to the Guardianship Assistance program are as follows: 1. The kinship guardianship assistance agreement must be a written and binding document entered into through negotiations with the prospective relative guardian and contain information concerning; the amount of, and manner in which, each kinship guardianship assistance payment will be provided under the agreement, and the manner in which the payment may be adjusted periodically, in consultation with the relative guardian, based on the circumstances of the relative guardian and the needs of the child (42 USC 673(d)(1)(A)(i) and 673(d)(1)(B)(i)).) 2. The Title IV-E agency may amend its Title IV-E plan to provide for a definition of a ?child? as an individual who has not attained 19, 20, or 21 years old (as the Title IV-E agency may elect) (42 USC 675(8)(B)(iii)). This definition of a child will then permit payment of kinship guardianship assistance for a child who is over age 18 (where the Title IV-E agency does not determine that the child has a mental or physical disability which warrants the continuation of assistance up to age 21) only if such a youth is part of a kinship guardianship assistance agreement that is in effect under Section 473 of the Social Security Act and the youth had attained 16 years of age before the agreement became effective. As an additional requirement, a youth over age 18 must also (as elected by the Title IV-E agency) be (a) completing secondary school (or equivalent); (b) enrolled in post-secondary or vocational school; (c) participating in a program or activity that promotes or removes barriers to employment; (d) employed 80 hours a month; or (e) incapable of any of these due to a documented medical condition (42 USC 675(8)(B)). Condition Of the sixty (60) samples selected for testing, we noted that for two (2) samples the form (KG 3) Kin-GAP Mutual Agreement for Nonminor Former Dependents was not provided. Therefore, we were not able to verify that the agreement for the participant was signed and was in effect when benefits were paid. This is a repeat finding of 2021-003. Cause The required form for participants, the Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG 3), could not be located. DCFS management represented that they were most likely misplaced. Effect The lack of documentation to support eligibility determinations results in questioned costs and noncompliance with 42 USC 673 and 42 USC 675. Questioned Costs $1,059 (known questioned costs based on FY 2021-22 assistance payments for the 2 samples) Context From a population of $33,700,076 of FY 2021-22 assistance payments, two (2) samples with total payments of $1,059 were noted. The sample was not a statistically valid sample. Recommendation We recommend that DCFS maintain required form Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG 3) in the Guardianship Assistance case files.

Reference Number: 2022-008 Federal Program Title: Sexually Transmitted Diseases (STD) Prevention and Control Grants Federal Assistance Listing Number: 93.977 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NH25PS005130-03-03; Year 2021 6 NH25PS005130-04-01; Year 2022 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the Sexually Transmitted Diseases (STD) Prevention and Control Grants program, we noted that DPH did not submit a FFATA report for one (1) of its subawards. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context One (1) subaward requiring the submission of a FFATA report was selected from a total population of two (2) subrecipient awards, and a report was not submitted for that one (1) subaward. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date and retain documentation evidencing submission of the report.

Reference Number: 2022-009 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-01-09; 6 NU50CK000498-02-04; 6 NU50CK000498-02-06; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement to file FFATA Reports for the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that DPH submitted the FFATA reports for three (3) subawards after the due date. See Schedule of Findings and Questioned Costs for chart/table. This is a repeat finding of 2021-006. Cause Due to limited staff and competing deadlines, it was an oversight that three (3) FFATA reports were not submitted. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Three (3) subawards requiring the submission of a FFATA report were selected from a total population of five (5) subawards, and three (3) subawards did not file FFATA reports timely. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Public Health strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.

Reference Number: 2022-010 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. 2 CFR ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our audit of the Department of Public Health?s (DPH) compliance with the reporting requirement for the HIV Prevention Activities Health Department Based program, we noted that DPH did not submit a FFATA report for nine (9) of its subawards. Cause Due to working on deadlines for the annual closing of multiple grants and claims submissions, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA reports results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Costs Questioned costs were not identified. Context Nine (9) subawards requiring the submission of a FFATA report were selected for testing from a total population of fifty two (52) subrecipient awards, and reports were not submitted for all nine (9) subawards selected. The sample was not a statistically valid sample. Recommendation We recommend that the DPH strengthen its report submission process to ensure all reports are identified and submitted by the defined due date, and retain documentation evidencing submission of the report.

Reference Number: 2021-001 Federal Program Title: Highway Planning and Construction Federal Assistance Listing Number: 20.205 Federal Agency: U.S. Department of Transportation Pass-Through Entity: California Department of Transportation Federal Award Number and Year: RPSTPLE -5953 (608); Fiscal Year 2020-21 Name of Department: Department of Public Works Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our review of the Highway Planning and Construction Program, we noted that the Department of Public Works (DPW) did not include documentation of their verification of suspension and debarment or include a contract clause or certification for one (1) vendor prior to entering into a covered transaction. Based on a subsequent review of the SAM exclusions, the vendor is not suspended or debarred. Cause DPW relied on the Internal Services Department to deactivate suspended and debarred vendors from eCAPS prior to entering into a covered transaction. If a vendor?s profile is deactivated, documents and transactions will not validate in eCAPS. Effect Failure to document verification of suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the six (6) contracts selected for testing, which totaled $3,570,307 from a population of $7,337,707 and forty one (41) contracts, there was one (1) vendor without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. This was not a statistically valid sample. Recommendation We recommend that DPW either: 1) include a contract clause or condition to the covered transaction with that person, 2) check the SAM exclusions prior to entering into a contract and maintain documentation of that verification, or 3) collect a certification from that person.

Reference Number: 2021-002 Federal Program Title: Community Services Block Grant (CSBG) Federal Assistance Listing Number: 93.569 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Community Services and Development Federal Award Number and Year: 20F-3021, 20F-3105, 20F-3660, 20F-3744, 21F-4021; 21F-4105 Fiscal Year 2020-21 Name of Department: Department of Public Social Services Category of Finding: Special Tests and Provisions ? Tri-Partite Board Compliance Criteria In accordance with 42 United States Code (U.S.C.) ?9910(b) Tri-Partite Boards, a public organization shall administer the Community Services Block Grant (CSBG) program through a Tri-Partite board, which shall have members selected by the organization and shall be composed so as to assure that not fewer than one-third of the members are persons chosen in accordance with the democratic selection procedures adequate to assure that these members: 1. Are representative of low-income individuals and families in the neighborhood served; 2. Reside in the neighborhood served; and 3. Are able to participate actively in the development, planning, implementation, and evaluation of programs funded under this chapter. Per California Government Code ?12751, the Tri-Partite board shall have: 1. One-third of the members be elected public officials, currently holding office, or their representatives; 2. At least one-third of the members are persons chosen in accordance with democratic selection procedures to represent the poor and reside in the area served; and 3. The remainder of the members are officials or members of business, industry, labor, religious, human services, education, or other major groups and interests in the community. In addition, per the California 2020-2021 CSBG State Plan and Application (for periods from October 1, 2019 to September 30, 2020, and from October 1, 2020 to September 30, 2021), if a board vacancy of more than 12 months is identified during monitoring procedures, the California Department of Community Services and Development (CSD) determines it as a finding. Condition The Tri-Partite board administered for the Department of Public Social Services (DPSS) CSBG program is designed as a fifteen (15)-member board divided into three sectors: public, low-income, and private, which is equally represented by five (5) members for each sector. Per our review of the Tri-Partite board roster at July 2020 and June 2021, we noted the following two (2) vacancies during FY 2020-21. See Schedule of Findings and Questioned Costs for chart/table. In CSD?s monitoring report number C-20-025 dated December 18, 2020, CSD issued a finding over the DPSS Tri-Partite board?s long-term vacancies and indicated that the vacancies must be filled no later than December 31, 2021. The vacancies were filled on August 19, 2021 and November 18, 2021, after the fiscal year-end date of June 30, 2021. However, according to the California 2020-2021 CSBG State Plan and Application, vacancies over 12 months are considered as a finding. Cause DPSS demonstrated good faith efforts by conducting outreach events to fill the vacancies and is working with CSD closely to meet the requirements. However, the response rate from the community is very low, and DPSS cannot force any individuals to join the board. Effect Long-term vacancies on the Tri-Partite board reduce low-income representation to below the one-third minimum requirement, resulting in noncompliance with 42 U.S.C. ?9910(b) and California Government Code ?12751. Questioned Costs No questioned costs were identified. Context Of the fifteen (15)-member Tri-Partite board, there were two (2) vacancies from the low-income sector as of June 30, 2021. The vacancies reduced low-income representation below the one-third minimum requirement. This is a repeat finding as indicated in the Status of Prior Years? Findings, as finding number 2020-005. Recommendation We recommend that DPSS continue to work with CSD to fill the vacancies.

Reference Number: 2021-003 Federal Program Title: Guardianship Assistance Federal Assistance Listing: 93.090 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No.16/17-69, 14/15-40, 11/12-18; Fiscal Year 2020-21 Name of Department: Department of Children and Family Services Category of Finding: Eligibility Criteria The compliance criteria pertaining to the Guardianship Assistance program are as follows: 1. The kinship guardianship assistance agreement must be a written and binding document entered into through negotiations with the prospective relative guardian and contain information concerning; the amount of, and manner in which, each kinship guardianship assistance payment will be provided under the agreement, and the manner in which the payment may be adjusted periodically, in consultation with the relative guardian, based on the circumstances of the relative guardian and the needs of the child (42 USC 673(d)(1)(A)(i) and 673(d)(1)(B)(i)).) 2. The Title IV-E agency may amend its Title IV-E plan to provide for a definition of a ?child? as an individual who has not attained 19, 20, or 21 years old (as the Title IV-E agency may elect) (42 USC 675(8)(B)(iii)). This definition of a child will then permit payment of kinship guardianship assistance for a child who is over age 18 (where the Title IV-E agency does not determine that the child has a mental or physical disability which warrants the continuation of assistance up to age 21) only if such a youth is part of a kinship guardianship assistance agreement that is in effect under Section 473 of the Social Security Act and the youth had attained 16 years of age before the agreement became effective. As an additional requirement, a youth over age 18 must also (as elected by the Title IV-E agency) be (a) completing secondary school (or equivalent); (b) enrolled in post-secondary or vocational school; (c) participating in a program or activity that promotes or removes barriers to employment; (d) employed 80 hours a month; or (e) incapable of any of these due to a documented medical condition (42 USC 675(8)(B)). Condition Of the sixty (60) samples selected for testing, we noted the following exceptions: 1. One (1) sample where the form (SOC 369) Agency-Relative Guardianship Disclosure was not signed by the case social worker. 2. Two (2) samples where there was no form (KG 3) Kin-GAP Mutual Agreement for Nonminor Former Dependents. Therefore, we were not able to verify that the agreement for the participant was signed and was in effect when benefits were paid. 3. One (1) sample where there was no form (KG 1) Kin-GAP Mutual Agreement for 18 Year Olds. Therefore, we were not able to verify that the agreement for the participant was signed and was in effect when benefits were paid. Cause The required forms for participants, which include the Agency-Relative Guardianship Disclosure (SOC369), Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG3) and Kin-GAP Mutual Agreement for 18 Year Olds (KG1), could not be located. DCFS management represented that they were most likely misplaced. Effect The lack of documentation to support eligibility determinations results in questioned costs and noncompliance with 42 USC 673 and 42 USC 675. Questioned Costs $32,635 (known questioned costs based on FY 2020-21 assistance payments for the 3 samples) Context From a population of $34,259,698 of FY 2020-21 assistance payments, three (3) samples with total payments of $32,635 are noted with the following exceptions: 1. One (1) sample, totaling $13,935 did not have a signed form (SOC 369) Agency-Relative Guardianship Disclosure in the case file. 2. One (1) sample, totaling $9,613, did not have a signed and completed form (KG 3) Kin-GAP Mutual Agreement for Nonminor Former Dependents in the case file. 3. One (1) sample, totaling $9,087, a. Did not have a signed and completed form (KG 3) Kin-GAP Mutual Agreement for Nonminor Former Dependents in the case file; and b. Did not have form (KG 1) Kin-GAP Mutual Agreement for 18 Year Olds in the case file. The sample was not a statistically valid sample. Recommendation We recommend that DCFS maintain required documentation and forms for Agency-Relative Guardianship Disclosure (SOC369), Kin-GAP Mutual Agreement for Nonminor Former Dependents (KG3) and Kin-GAP Mutual Agreement for 18 Year Olds (KG1) for the Guardianship Assistance case files.

Reference Number: 2021-004 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: U3REP190604, U3REP190604-02-00, 1U3REP190604-01-00, 6U3REP190604-01-01, 6U3REP190604-01-03, U3REP200652; Fiscal Year 2020-21 Name of Department: Department of Health Services Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200, a covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our review of the National Bioterrorism Hospital Preparedness Program, we noted that five (5) vendor contracts reviewed did not include a suspension and debarment certification clause requiring the vendor to certify that it was not suspended or debarred from participation in federally funded contracts. There was no other documentation available to demonstrate that the verification of suspension and debarment was performed prior to entering into the covered transactions. Based on a subsequent review of the SAM exclusions, those five (5) vendors are not suspended or debarred. Cause The contracts for all five (5) vendors only includes standard terms and conditions regarding contractor responsibility and debarment. This lists the circumstances in which the County can debar a contractor but does not include specific language certifying the contractor is not suspended or debarred prior to entering into the contract. The clause in the contract must specifically state the entity is not suspended or debarred, not just state the terms and conditions that could lead to debarment. Effect Failure to verify suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context We selected five (5) vendors for testing, whose contract expenditures totaled $7,439 from a population of twelve (12) vendors and $15,959. There was no evidence available that the verification of suspension and debarment was performed before entering into a covered transaction for all five (5) vendors selected. This was not a statistically valid sample. In addition, this is a repeat finding as indicated in the Status of Prior Years? Findings as finding number 2020-009. Recommendation We recommend that DHS check the SAM exclusions prior to entering into a contract, maintain documentation of that verification, and add a clause to the contract that requires vendors to certify that they are not suspended or debarred

Reference Number: 2021-005 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-02-06; Fiscal Year 2020-21 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modifications. (1) Federal award identification: (ii) Subrecipient?s unique entity identifier [generally the Data Universal Numbering System (DUNS) number] (iii) Federal Award Identification Number (FAIN) (xiii) Identification of whether the award is R&D (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ?200.414 Condition During our review of the Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we selected two (2) subrecipient samples with active contracts with the Department of Public Health (DPH) during FY 2020-21 and noted that DPH did not identify the subrecipients? DUNS number, FAIN, identification whether the award is R&D, and the indirect cost rate at the time of subaward to the subrecipients. Cause It was an oversight by DPH personnel that information was not communicated to the subrecipients. Effect Failure to provide all the required subaward information results in noncompliance with 2 CFR ?200.332(a). In addition, the subrecipients may not report or incorrectly report the federal award information in their Single Audit reports. Questioned Costs Questioned costs were not identified. Context For the two (2) subrecipients selected for testing, which totaled $17,194,620 from a population of five (5) subrecipient expenditures totaling $25,440,227, DPH did not communicate four (4) of the required subaward data elements: the subrecipients DUNS number, FAIN, identification whether the award is R&D, and the indirect cost rate. The sample was not a statistically valid sample. Recommendation We recommend that DPH perform the following procedures: 1. Provide the subaward information as required by 2 CFR ?200.332(a) to subrecipients at the time of the subaward and communicate any changes in subsequent subaward modifications. 2. For existing subrecipients that were not previously provided the required elements, ensure they are communicated prior to the end of FY 2021-22. 3. Consider including placeholders for required subaward information in the contract template, which could be removed if not applicable.

Reference Number: 2021-006 Federal Program Title: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Federal Assistance Listing Number: 93.323 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 6 NU50CK000498-02-06; Fiscal Year 2020-21 Name of Department: Department of Public Health Category of Finding: Reporting Criteria In accordance with Title 2 Code of Federal Regulations (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a Federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During our review of the FFATA Reports required to be filed for Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) program, we noted that four (4) FFATA reports were not filed as required and two (2) expenditure reports were submitted after due date. Additionally, the program was unable to provide proof of timely submission and approval for four (4) Performance Measure reports. See Schedule of Findings and Questioned Costs for chart/table. Cause Due to working on deadlines for the closing of grants and claims submission, it was an oversight that four (4) FFATA reports were not submitted and two (2) Expenditure Reports were not submitted on a timely basis. The program has daily meetings to highlight the report information with the Principal Investigator and Team Lead in which reporting performance measures are analyzed. However, the reporting information analyzed during the daily meeting is not documented. The program staff enters the data directly into the REDCap system for the Performance Measure reports without a review process or documenting date of submission. Effect Failure to submit the FFATA reports on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Failure to submit the Expenditure and Performance Measure reports on a timely basis along without documenting proper approval process is a deficiency in internal control over compliance with 2 CFR ?200.303(a). Questioned Costs Questioned costs were not identified. Context Four (4) out of four (4) of the required FFATA reports were not submitted. Two (2) out of seven (7) selected Expenditure reports were not submitted on a timely basis. Four (4) out of four (4) selected Performance Measure reports had no proof of timely submission or documentation that the reporting information was properly approved. The sample was not a statistically valid sample. Recommendation We recommend that DPH strengthen its report submission process to ensure all reports are submitted and approved on a timely basis.

Reference Number: 2021-007 Federal Program Title: National Bioterrorism Hospital Preparedness Program Federal Assistance Listing Number: 93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: U3REP190604, U3REP190604-02-00, 1U3REP190604-01-00, 6U3REP190604-01-01, 6U3REP190604-01-03, U3REP200652; Fiscal Year 2020-21 Name of Department: Department of Health Services Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200, a covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our review of the National Bioterrorism Hospital Preparedness Program, we noted that twenty (20) subrecipient agreements reviewed indicated the SAM verification occurred after the execution of the contract. There was no other documentation available to demonstrate that the verification of suspension and debarment was performed prior to entering into the covered transactions. Based on subsequent review of the SAM exclusions, those twenty (20) subrecipients are not suspended or debarred. Cause During the audit of FY 2019-20 agreements, DHS discovered that the debarment clause in the Specialty Care Center Designation Master Agreement had been omitted and this omission was not corrected until Spring 2021. Once DHS became aware of this issue, they took action to correct the issue but the FY 2020-21 agreements had already been executed. DHS then reviewed all contractors for debarment in SAMS and found that no entity had a federal debarment. However, this occurred after the contract date. Effect Failure to verify suspension and debarment prior to the contract date results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds may be used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the twenty (20) subrecipients selected for testing, which totaled $5,429,035 from a population of $7,028,635 and ninety-one (91) subrecipients, there were twenty (20) subrecipients in which the verification of suspension and debarment was performed after the contract date occurred. This was not a statistically valid sample. In addition, this is a repeat finding as indicated in the Status of Prior Years? Findings as finding number 2020-009. Recommendation We recommend that DHS check the SAM exclusions prior to entering into a contract, maintain documentation of that verification, and add a clause to the contract that requires subrecipients to certify they are not suspended or debarred.

Reference Number: 2021-008 Federal Program Title: 2018 HAVA Election Security Grants Federal Assistance Listing Number: 90.404 Federal Agency: U.S. Election Assistance Commission Pass-Through Entity: California Secretary of State Federal Award Number and Year: 20G26119; Fiscal Year 2020-21 Name of Department: Registrar-Recorder/County Clerk Category of Finding: Procurement and Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulations (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our review of the 2018 HAVA Election Security Grants program, we noted that fourteen (14) vendor contracts reviewed did not include a suspension and debarment certification clause indicating the vendor was not suspended or debarred from participation in federally funded contracts. There was no other documentation available to demonstrate that the verification of suspension and debarment was performed prior to entering into the covered transactions. Based on a subsequent review of the SAM exclusions, those fourteen (14) vendors are not suspended or debarred. Cause The contracts for all fourteen (14) vendors only include standard terms and conditions regarding contractor responsibility and debarment. This lists the circumstances in which the County can debar a contractor but does not include specific language certifying the contractor is not suspended or debarred prior to entering into the contract. The clause in the contract must specifically state the entity is not suspended or debarred, not just state the terms and conditions that could lead to debarment. Effect Failure to verify suspension and debarment before entering into contract could result in noncompliance with 2 CFR ?180.300, as there is a risk that federal funds may be used to pay vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified. Context Of the fourteen (14) vendors selected for testing, which totaled $5,662,940 from a population of eighty-six (86) and $13,331,041, there were fourteen (14) vendors without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. This was not a statistically valid sample. Recommendation We recommend that Registrar-Recorder/County Clerk check the SAM exclusions prior to entering into a contract, maintain documentation of that verification, and add a clause to the contract that requires vendors to certify that they are not suspended or debarred.

Reference Number: 2021-009 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: N/A Name of Department: County Executive Office Department of Public Health Department of Health Services Department of Workforce Development, Aging and Community Services Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modifications. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our review of the Coronavirus Relief Fund (CRF) program, we selected nine (9) subrecipients with active contracts with the County administered by the County Executive Office (CEO), Department of Public Health (DPH), Department of Health Services (DHS) and Department of Workforce Development, Aging and Community Services during FY 2020-21 and noted that these departments did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. One (1) subrecipient agreement did not identify the funding as federal. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. Cause The CRF program is a new program and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $228,935,954 from a population of one hundred (100) subrecipients with expenditures totaling $315,799,135, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County consider the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g. data encryption requirements). Incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.

Reference Number:2020-002 Federal Program Title: MaryLee Allen Promoting Safe and Stable Families Program Federal Catalog Number: 93.556 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No. 19/20-19; Fiscal Year 2019-20 Name of Department: Department of Children and Family Services Category of Finding: Earmarking Criteria In accordance with the County Fiscal Letter (CFL) No. 19/20-19 issued by the California Department of Social Services (CDSS), the County received $7,802,970 of MaryLee Allen Promoting Safe and Stable Families (PSSF) Program funds and was required to spend a minimum of 20 percent of these program funds on each of the four program components: (1) Family Preservation Services (2) Family Support Services (3) Adoption Promotion and Support (4) Time-Limited Family Reunification Per CFL No. 19/20-35, the County also received $408,405 for the PSSF program and was required to use these funds for improving the quality of monthly caseworker visits with an emphasis on caseworker decision-making and caseworker recruitment and retention. Therefore, the County received a total of $8,211,375 of PSSF program funds in FY 2019-20. Condition During our review of the four quarterly County Expense Claims (CEC) submitted for FY 2019-20, we noted that the Department of Children and Family Services (DCFS) did not spend a minimum of 20 percent of PSSF program funds on the Time-Limited Family Reunification (TLFR) and the Family Preservation Services (FPS) components. Cause DCFS has a memorandum of understanding with the County?s Department of Public Health (DPH) to provide substance abuse treatment services for the TLFR. Due to a Medi-Cal waiver that allows DPH to bill additional substance abuse treatment service costs to the Medi-Cal program, DPH billed more costs to the Medi-Cal program and less to the TLFR, which caused DCFS to be out of compliance with the earmarking requirement. DCFS had informed CDSS in FY 2018-19 and prepared a quality improvement plan (QIP). The QIP indicates that DCFS will utilize the 20 percent of TLFR funding on FPS starting July 1, 2020. The State approved the QIP in May 2020. Since the implementation of QIP did not start in FY 2019-20, the minimum 20 percent requirement was not met. DCFS management believes that the FPS expenditures of $1,540,000, which represents 19.74 percent of the funding, could be rounded up to meet the minimum 20 percent requirement. Therefore, no additional funds were utilized on FPS. Effect Failure to spend the required minimum of 20 percent of program funds on the TLFR and FPS results in noncompliance with CFL No. 19/20-19. Questioned Costs $1,534,179 (known questioned costs based on the minimum 20 percent requirement compared to the actual amount spent on TLFR) $20,594 (known questioned costs based on the minimum 20 percent requirement compared to the actual amount spent on FPS) Context Of the $8,211,375 expenditures claimed, $7,802,970 is subject to the minimum 20 percent earmarking requirement, which requires DCFS to spend at least $1,560,594 on each program component. However, DCFS spent $26,415 or 0.34 percent of the PSSF program funds on the TLFR component and $1,540,000 or 19.74 percent on the FPS component, which did not meet the requirement. This is a repeat finding as indicated in the Status of Prior Years? Findings, as finding number 2019-001. Recommendation We recommend that DCFS follow its approved QIP to reallocate the 20 percent of PSSF funding from TLFR to FPS starting in FY 2020-21 and ensure each of the other components meets the minimum 20 percent requirement without rounding.

Reference Number:2020-003 Federal Program Title:Temporary Assistance for Needy Families Federal Catalog Number:93.558 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Social Services Federal Award Number and Year:CFL No. 19/20-04; Fiscal Year 2019-20 Name of Department:Department of Children and Family Services Category of Finding:Allowable Costs/Cost Principles Federal Program Title:Foster Care Title IV-E Federal Catalog Number:93.658 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Social Services Federal Award Number and Year:CFL No. 19/20-04, 19/20-07; Fiscal Year 2019-20 Name of Department:Department of Children and Family Services Category of Finding:Allowable Costs/Cost Principles Federal Program Title:Adoption Assistance Federal Catalog Number:93.659 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Social Services Federal Award Number and Year:CFL No. 11/12-18, 14/15-40, 16/17-69; Fiscal Year 2019-20 Name of Department:Department of Children and Family Services Category of Finding:Allowable Costs/Cost Principles Federal Program Title: John H. Chafee Foster Care Program for Successful Transition to Adulthood Federal Catalog Number: 93.674 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Social Services Federal Award Number and Year:CFL No. 19/20-60; Fiscal Year 2019-20 Name of Department: Department of Children and Family Services Category of Finding:Allowable Costs/Cost Principles Criteria Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The Department of Children and Family Services (DCFS) has common internal controls over the direct and indirect payroll process for its federal programs. We selected one hundred and eighteen (118) employees, two timesheets for each employee for a total of two hundred and thirty-six (236) timesheets, to test allowable costs and the internal controls over direct and indirect payroll. Eighty (80) timesheets represented indirect payroll expenditures allocated to the DCFS major programs. One hundred and fifty-six (156) timesheets represented direct payroll expenditures selected from each of the four major programs below: 1. CFDA No. 93.558 Temporary Assistance for Needy Families (TANF): Twenty-four (24) timesheets 2. CFDA No. 93.658 Foster Care Title IV-E: Forty-six (46) timesheets 3. CFDA No. 93.659 Adoption Assistance: Eighty (80) timesheets 4. CFDA No. 93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood ? Six (6) timesheets During our review of the payroll transactions, one (1) timesheet for indirect payroll and one (1) timesheet for direct payroll from the TANF program were not approved timely. (See Schedule of Findings and Questioned Costs for table.) Cause The timesheets were initially submitted electronically and placed on draft/rejected status since corrections needed to be made. Due to an oversight, the manual timesheet corrections were not submitted and approved until the transactions were selected for our review. Effect The late approval of employee timesheet are deficiencies in internal control over compliance with 2 CFR ?200.303(a), which could result in unallowable costs claimed. Questioned Costs No questioned costs were identified. Context Of the eighty (80) timesheets from forty (40) employees, totaling $294,396, selected from the DCFS indirect payroll population of $168,782,079, the timesheet for one (1) employee, totaling $2,194, was not approved timely. Of the one hundred fifty-six (156) timesheets from seventy-eight (78) employees, totaling $67,130, selected from a population of $388,465,838, the timesheet for one (1) employee for the TANF program, totaling $3,378 was not approved timely. However, we did not identify these costs as unallowable. The sample was not a statistically valid sample. In addition, this is a repeat finding for the TANF payroll as indicated in the Status of Prior Years? Findings, as finding number 2019-004. Recommendation We recommend that DCFS strengthen its review process to ensure all timesheets and manual corrections are approved in a timely manner.

Reference Number:2020-004 Federal Program Title:Adoption Assistance Federal Catalog Number:93.659 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Social Services Federal Award Number and Year:CFL No. 11/12-18, 14/15-40, 16/17-69; Fiscal Year 2019-20 Name of Department:Department of Children and Family Services Category of Finding:Activities Allowed or Unallowed and Eligibility Criteria The compliance criteria pertaining to the Adoption Assistance program are as follows: The prospective adoptive parents must satisfactorily have met a criminal records check, including a fingerprint-based check (42 USC 671(a)(20)(A)), which involves a determination that such individuals have not committed any prohibited felonies in accordance with 42 USC 671(a)(20)(A)(i) and (ii). In addition, the prospective adoptive parents and any other adult living in the home who has resided in the provider home in the preceding 5 years must satisfactorily have met a child abuse and neglect registry check under 42 USC 671(a)(20)(B). The agreement for the subsidy was signed and was in effect before the final decree of adoption and contains information concerning the nature of services; the amount and duration of the subsidy; the child?s eligibility for Title XX services and Title XIX Medicaid; and covers the child should he/she move out of State with the adoptive family (42 USC 675(3)). Condition Of the sixty (60) samples selected for testing, we noted the following exceptions: 1. Three (3) samples where there was no criminal record check, as well as child abuse and neglect registry check in the case file. 2. Two (2) samples where there was no final decree of adoption in the case file. Therefore, we were not able to verify that the agreement for the subsidy was signed and was in effect before the final decree of adoption. Eligibility of Adoption Assistance Program cases is determined when the cases are initiated. No redetermination is required and eligible children can receive benefits until the age of 18 (or 21 if they meet specific requirements). Therefore, documentation of eligibility determination for some cases was prepared in the late 1990s or early 2000s, and the children in those cases could receive benefits in FY 2019-20 since they had not reached the age of 18 (or 21). Prior to 2010, there were many deficiencies in DCFS? documentation of eligibility determination for the program. In 2010, DCFS implemented procedures to improve the accuracy and completeness of their documentation. Three (3) out of the four (4) samples noted in this finding are cases that were initiated prior to 2010. Cause The criminal record check, the child abuse and neglect registry check, and the final decree of adoption could not be located. DCFS management represented that they were most likely misplaced. Effect The lack of documentation to support allowable activities and eligibility determinations results in questioned costs and noncompliance with 42 USC 675 and 42 USC 671. Questioned Costs $47,230 (known questioned costs based on FY 2019-20 assistance payments for the 4 samples) Context From a population of $146,000,290 of FY 2019-20 assistance payments, four (4) samples with total payments of $47,230 are noted with the following exceptions: 1. Two (2) samples, totaling $20,952, did not have a criminal record check, as well as a child abuse and neglect registry check in the case file. 2. One (1) sample, totaling $18,082, a. Did not have a criminal record check, as well as a child abuse and neglect registry check in the case file; and b. Did not have an adoption order (ADOPT-215) in the case file. 3. One (1) sample, totaling $8,196, did not have an adoption order (ADOPT-215) in the case file. The sample was not a statistically valid sample. In addition, this is a repeat finding as indicated in the Status of Prior Years? Findings, as finding numbers 2019-002 and 2018-005. Recommendation We recommend that DCFS maintain required documentation of criminal record checks, child abuse and neglect registry checks, and adoption order for adoption case files.

Reference Number:2020-005 Federal Program Title:Community Services Block Grant (CSBG) Federal Catalog Number:93.569 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Community Services and Development Federal Award Number and Year: 19F-4021, 19F-4423, 20F-3021; Fiscal Year 2019-20 Name of Department:Department of Public Social Services Category of Finding:Special Tests and Provisions ? Tripartite Board Compliance Criteria In accordance with 42 United States Code (U.S.C.) ?9910(b) Tripartite Boards, a public organization shall administer the Community Services Block Grant (CSBG) program through a tripartite board, which shall have members selected by the organization and shall be composed so as to assure that not fewer than one-third of the members are persons chosen in accordance with the democratic selection procedures adequate to assure that these members: 1. Are representative of low-income individuals and families in the neighborhood served; 2. Reside in the neighborhood served; and 3. Are able to participate actively in the development, planning, implementation, and evaluation of programs funded under this chapter. Per California Government Code ?12751, the tripartite board shall have: 1. One-third of the members be elected public officials, currently holding office, or their representatives; 2. At least one-third of the members are persons chosen in accordance with democratic selection procedures to represent the poor and reside in the area served; and 3. The remainder of the members are officials or members of business, industry, labor, religious, human services, education, or other major groups and interests in the community. In addition, per the California 2020-2021 CSBG State Plan and Application (for period from October 1, 2019 to September 30, 2020), if a board vacancy of more than 12 months is identified during monitoring procedures, the California Department of Community Services and Development (CSD) determines it as a finding. Condition The tripartite board administered for the Department of Public Social Services (DPSS) CSBG program is designed as a fifteen (15)-member board divided into three sectors: public, low-income, and private, which is equally represented by five (5) members for each sector. Per our review of the tripartite board roster at July 2019 and June 2020, we noted the following three (3) vacancies during FY 2019-20. (See Schedule of Findings and Questioned Costs for table.) In CSD?s monitoring report number C-19-025 dated April 25, 2019, CSD issued a finding over the DPSS tripartite board?s long-term vacancies and indicated that the vacancies must be filled no later than March 31, 2020. However, those vacancies were not filled by the due date. CSD performed another review and issued a report in December 2020, which indicated a repeat finding of the long-term vacancies and expected that DPSS fill the vacancies no later than December 31, 2021. DPSS indicated this is an extension from the previous due date of March 31, 2020. However, according to the California 2020-2021 CSBG State Plan and Application, vacancies over 12 months are still considered as a finding. Cause DPSS demonstrated good faith efforts by conducting outreach events to fill the vacancies and is working with CSD closely to meet the requirements. However, the response rate from the community is very low, and DPSS cannot force any individuals to join the board. Effect Long-term vacancies on the tripartite board reduce low-income and public representation to below the one-third minimum requirement, resulting in noncompliance with 42 U.S.C. ?9910(b) and California Government Code ?12751. Questioned Costs No questioned costs were identified. Context Of the fifteen (15)-member tripartite board, there were two (2) vacancies from the low- income sector and one (1) vacancy from the public sector as of June 30, 2020. The vacancies reduced representation below the one-third minimum requirement. Recommendation We recommend that DPSS continue to work with CSD to fill the vacancies.

Reference Number:2020-006 Federal Program Title:Community Services Block Grant (CSBG) Federal Catalog Number:93.569 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:California Department of Community Services and Development Federal Award Number and Year:19F-4105, 19F-4458, 20F-3105; Fiscal Year 2019-20 Name of Department:Department of Workforce Development, Aging and Community Services Category of Finding:Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.331, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of the data elements change, the changes are included in subsequent subaward modifications. (1) Federal award identification: (ii) Subrecipient?s unique entity identifier [generally the Data Universal Numbering System (DUNS) number] (iii) Federal Award Identification Number (FAIN) (xiii) Identification of whether the award is R&D Condition During our review of the Community Services Block Grant (CSBG) program, we selected two (2) subrecipient samples with active contracts with the Department of Workforce Development, Aging and Community Services (WDACS) during FY 2019-20, and noted that WDACS did not identify the subrecipients DUNS number, FAIN, and whether the award is R&D at the time of subaward to the subrecipients. Cause It was an oversight by WDACS personnel that information was not communicated to the subrecipients. Effect Failure to provide all the required subaward information results in noncompliance with 2 CFR ?200.331(a). In addition, the subrecipients may not report or incorrectly report the federal award information in their Single Audit reports. Questioned Costs Questioned costs were not identified. Context For the two (2) subrecipients selected for testing, which totaled $199,866 from a population of $280,929, the WDACS did not communicate three (3) of the required subaward data elements: the subrecipients DUNS number, FAIN, and whether the award is R&D. The samples tested were not statistically valid samples. Recommendation We recommend that WDACS perform the following procedures: 1. Develop a standard template to include the subaward information as required by 2 CFR ?200.331(a) and provide it to subrecipients at the time of the subaward and communicate any changes in subsequent subaward modifications. 2. For existing subrecipients that were not previously provided the required elements, ensure they are communicated prior to the end of FY 2020-21.

Reference Number:2020-007 Federal Program Title: Public Health Emergency Preparedness Federal Catalog Number:93.069 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:N/A Federal Award Number and Year:1 NU90TP922022-01; Fiscal Year 2019-20 Name of Department:Department of Public Health Category of Finding:Level of Effort Criteria In accordance with 42 United States Code (U.S.C.) ?247d-3a, an entity that receives an award under this section shall maintain expenditures for public health security at a level that is not less than the average level of such expenditures maintained by the entity for the preceding two-year period. Per the grant agreement issued by the Centers for Disease Control and Prevention, awardees must maintain expenditures for health care preparedness and public health security at a level that is not less than the average level of such expenditures maintained by the awardee for the preceding two-year period. This represents an awardee?s historical level of contributions or expenditures (money spent) related to federal programmatic activities that have been made prior to the receipt of federal funds. Condition During our review of the Public Health Emergency Preparedness program, we noted that the FY 2019-20 actual expenditures for public health security were less than the average level of such expenditures maintained by the County?s Department of Public Health (DPH) for the preceding two-year period. Cause DPH budgeted and planned to spend expenditures necessary to maintain expenditures for public health security at a level that would not be less than the average of such expenditures of the preceding two-year period. However, due to the COVID-19 pandemic, some employees whose payroll costs were initially budgeted for public health security activities were deployed to respond to the COVID-19 public health emergency, and those payroll costs were reimbursed by COVID-19 funding from the Centers for Disease Control and Prevention. As such, DPH was not able to meet the requirement. Effect Not maintaining actual expenditures for health care preparedness at a level that is not less than the average level of such expenditures maintained for the preceding two years results in noncompliance with 42 U.S.C ?247d-3a and the grant agreement. Questioned Costs No questioned costs were identified. Context The average level of expenditures for public health emergency preparedness maintained by DPH for the preceding two-year period were $6,045,630. However, the actual expenditures spent for FY 2019-20 was $5,837,015, which is $208,615 less than the average of the preceding two-year period. Recommendation We recommend that DPH maintain the required expenditures levels regardless whether there are additional revenues to reimburse part of the public health security activities. When DPH is unable to meet the level of effort requirement, DPH should obtain written approval from the funding agency waiving such requirement.

Reference Number:2020-008 Federal Program Title:National Bioterrorism Hospital Preparedness Program Federal Catalog Number:93.889 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity:N/A Federal Award Number and Year:1 NU90TP921934-01, 6 U3REP190604-01; Fiscal Year 2019-20 Name of Department:Department of Health Services Category of Finding:Reporting Criteria In accordance with Title 2 Code of Federal Regulation (CFR) Part 170 ? Reporting Subaward and Executive Compensation Information, Appendix A to Part 170 ? Award Term, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $25,000. Condition During our review of five (5) financial reports and one (1) performance report, we noted that one financial (1) report was submitted after the due date. (See Schedule of Findings and Questioned Costs for table.) Cause Due to working on deadlines for the annual closing of grants and claims submission, it was an oversight that the FFATA report was not submitted on time. Effect Failure to submit the FFATA report on a timely basis results in noncompliance with the reporting requirements with 2 CFR Part 170. Questioned Cost Questioned costs were not identified. Context Of the six (6) reports selected from a total population of twenty (20) reports for testing, one (1) report was submitted 227 days after the due date. The sample was not a statistically valid sample. Recommendation We recommend that the Department of Health Services strengthen its report submission process to ensure all reports are submitted timely.

Reference Number:2020-009 Federal Program Title:National Bioterrorism Hospital Preparedness Program Federal Catalog Number:93.889 Federal Agency:U.S. Department of Health and Human Services Pass-Through Entity:N/A Federal Award Number and Year:1 NU90TP921934-01, 6 U3REP190604-01; Fiscal Year 2019-20 Name of Department:Department of Health Services Category of Finding:Suspension and Debarment Criteria In accordance with Title 2 Code of Federal Regulation (CFR) ?180.200. A covered transaction is a nonprocurement or procurement transaction that is subject to the prohibitions of this part. Per 2 CFR ?180.970(a), nonprocurement transaction means any transaction, regardless of type (except procurement contracts), including, but not limited to grants. According to 2 CFR ?180.300, when the County enters into a covered transaction with another person at the next lower tier, the County must verify that the person is not excluded or disqualified. The County can do this by: 1. Checking System for Award Management (SAM) exclusions 2. Collecting a certification from that person; or 3. Adding a clause or condition to the covered transaction with that person. Per 2 CFR ?180.985 Person, person means any individual, corporation, partnership, association, unit of government, or legal entity, however organized. Condition During our review of the National Bioterrorism Hospital Preparedness Program, we noted that twenty-two (22) subrecipient agreements reviewed did not include a suspension and department certification clause indicating the subrecipient was not suspended or debarred from participation in federally funded contracts. There was no other documentation available to demonstrate that the verification of suspension and debarment was performed prior to entering into the covered transactions. Based on subsequent review of the SAM exclusions, those twenty-two (22) subrecipients are not suspended or debarred. In addition, the County Department of Health Services (DHS) provided a printout from SAM to indicate that one (1) vendor was not suspended or debarred. However, we noted that the printout was dated on April 6, 2021, which was subsequent to the date the covered transaction occurred. Cause DHS determined that the clause regarding subrecipients certifying that they are not suspended or debarred was not applicable to hospitals who received program funding from DHS. Therefore, the clause was intentionally omitted from the agreements for twenty-two (22) out of twenty-three (23) subrecipients tested. The agreement for one (1) subrecipient tested has the clause because it was inadvertently included. Due to the COVID-19 pandemic, there was a significant shortage of personal protective equipment (PPE) used to protect healthcare workers. At the time the masks were ordered, DHS had not been awarded the supplemental COVID-19 funding for this program. Therefore, DHS proceeded with the purchase under the County?s emergency purchasing guidelines using non-federal funds and did not perform verification of suspension and debarment for the vendor. Subsequently, DHS received the supplemental COVID-19 funding for this program which allowed DHS to claim reimbursements for eligible expenditures incurred from January 20, 2020. Therefore, DHS decided to use a portion of the funding to cover the costs of the masks. Effect Failure to verify suspension and debarment results in noncompliance with 2 CFR ?180.300, and there is a risk that federal funds are used to pay subrecipients and vendors that are suspended or debarred. Questioned Costs Questioned costs were not identified as the twenty-two (22) subrecipients and the one (1) vendor are not suspended or debarred. Context Of the twenty-three (23) subrecipients selected for testing, which totaled $4,413,496 from a population of $6,451,809, there were twenty-two (22) subrecipients without evidence that the verification of suspension and debarment was performed before entering into a covered transaction. Of the three (3) vendors selected for testing, which totaled $673,692 from a population of $922,372, the verification of suspension and debarment for one (1) vendor was performed after the covered transaction occurred. The sample tested was not a statistically valid sample. Recommendation We recommend that when awarding federal funds to subrecipients, DHS verify the SAM exclusions prior to entering into a contract and maintain documentation of the verification or add a clause to the contract that subrecipients certify they are not suspended or debarred by signing the contract. In addition, when federal funding is subsequently applied to a covered transaction, DHS check the SAM exclusions and collect a certification from the vendor prior to requesting reimbursements from federal funds.

Reference Number:2020-010 Federal Program Title:Coronavirus Relief Fund Federal Catalog Number:21.019 Federal Agency:U.S. Department of Treasury Pass-Through Entity:N/A Federal Award Number and Year:Fiscal Year 2019-20 Name of Department:Department of Public Health Category of Finding:Allowable Costs/Cost Principles Criteria Title 2 Code of Federal Regulations (2 CFR) ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). According to the reimbursement instructions issued by the County Chief Executive Office (CEO), County departments must submit supporting timesheets and activity logs to demonstrate time/hours reported. Condition During our review of the payroll transactions, we noted that one (1) payroll sample selected from the Department of Public Health (DPH) had the supporting timesheets; however, the activity log that describes the COVID-19 related activities performed by the employee was not provided. Cause DPH requires employees to submit activity logs for each pay period to their supervisors for review, and upon approval, supervisors are responsible for submitting the activity logs to DPH?s Documentation Unit. When an employee fails to submit an activity log, it is the supervisor?s responsibility to follow up with the employee. Regarding the payroll sample in this finding, the supervisor did not follow the procedure to obtain and submit the activity log to the Documentation Unit. Effect The missing activity log is a deficiency in internal control over compliance with 2 CFR ?200.303(a) and the CEO?s reimbursement instructions, which could result in unallowable costs claimed. Questioned Costs $5,571 (known questioned costs based on one payroll sample) Context Of the sixty (60) payroll samples, totaling $78,197, selected from a population of $77,301,892, the activity log for one (1) payroll sample was missing. The sample was not a statistically valid sample. Recommendation We recommend that DPH perform the following: 1. Provide training to employees and supervisors to ensure they understand and follow the procedures. 2. Designate personnel to verify reimbursement claims include all supporting timesheets and activity logs before submission to CEO.

Reference Number: 2019-001 Federal Program Title: Promoting Safe and Stable Families Federal Catalog Number: 93.556 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No. 18/19-34; Fiscal Year 2018-19 Name of Department: Department of Children and Family Services Category of Finding: Earmarking Criteria In accordance with the County Fiscal Letter (CFL) No. 18/19-34 issued by the California Department of Social Services (CDSS), the County received $8,055,423 of program funds and must spend a minimum of 20 percent of these Promoting Safe and Stable Families (PSSF) program funds on each of the four program components: (1) Family Preservation Services (2) Family Support Services (3) Adoption Promotion and Support (4) Time-Limited Family Reunification Per CFL No. 18/19-36, the County also received $406,219 for the PSSF program and could only use these funds for improving the quality of monthly caseworker visits with an emphasis on caseworker decision making and caseworker recruitment and retention. Therefore, the County received a total of $8,461,642 of PSSF program funds in FY 2018-19. Condition During our review of the four quarterly County Expense Claims (CEC) submitted for fiscal year (FY) 2018-19, we noted that the Department of Children and Family Services (DCFS) did not spend a minimum of 20 percent of PSSF program funds on the Time- Limited Family Reunification (TLFR) component. Cause DCFS has a memorandum of understanding with the County?s Department of Public Health (DPH) to provide substance abuse treatment services for the TLFR. Due to a Medi-Cal waiver that allows DPH to bill additional substance abuse treatment service costs to the Medi-Cal program, DPH billed more costs to the Medi-Cal program and less to the TLFR, which caused DCFS to be out of compliance for the earmarking requirement. DCFS had informed CDSS and was working on a plan to utilize additional funds on TLFR. Because the plan was not implemented in FY 2018-19, the minimum 20 percent requirement was not met. Effect Failure to spend the required minimum of 20 percent of program funds on the TLFR results in noncompliance with CFL No. 18/19-34. Questioned Costs $1,378,783 (known questioned costs based on the minimum 20 percent requirement compared to the actual amount spent on TLFR) Context Of the $8,461,642 expenditures claimed, $8,055,423 is subject to the minimum of 20 percent earmarking requirement, which requires DCFS to spend at least $1,611,085 on each program component. However, DCFS spent $232,302 or 3 percent of the PSSF program funds on the TLFR component, which did not meet the requirement. Recommendation We recommend that DCFS continues to work on a plan to spend a minimum of 20 percent of PSSF program funds on the TLFR.

Reference Number: 2019-002 Federal Program Title: Adoption Assistance Federal Catalog Number: 93.659 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No. 11/12-18, 14/15/-40, 16/17-69; Fiscal Year 2018-19 Name of Department: Department of Children and Family Services Category of Finding: Activities Allowed or Unallowed and Eligibility Criteria The compliance criteria pertaining to the Adoption Assistance program are as follows: 1. The child was determined by the Department of Children and Family Services (DCFS) to be a child with special needs. Special needs means that there is a specific factor or condition (such as ethnic background, age, or membership in a minority or sibling group, or the presence of factors such as medical conditions or physical, mental, or emotional handicaps) because of which it is reasonable to conclude that the child cannot be placed with adoptive parents without providing adoption assistance under Title IV-E and medical assistance under Title XIX (42 USC 673(c)(1)(B)). 2. Per DCFS? policies and procedures, the Adoption Assistance Program (AAP) 4 form ? Eligibility Certification, Section I Three Part Special Needs Determination or Barriers to Adoption section and the AD 4320 Adoption Assistance Program (AAP) Agreement should be completed. 3. The prospective adoptive parents must satisfactorily have met a criminal records check, including a fingerprint-based check (42 USC 671(a)(20)(A)), which involves a determination that such individuals have not committed any prohibited felonies in accordance with 42 USC 671(a)(20)(A)(i) and (ii). In addition, the prospective adoptive parents and any other adult living in the home who has resided in the provider home in the preceding 5 years must satisfactorily have a met child abuse and neglect registry check under 42 USC 671(a)(20)(B). 4. The child was determined by the Title IV-E agency as someone who cannot or should not be returned to the home of his or her parents (42 USC 673(c)(1)(A)). 5. The Title IV-E agency has made reasonable efforts to place the child for adoption without a subsidy. The only exception to this requirement is where it would be against the best interests of the child because of such factors as the existence of significant emotional ties with prospective adoptive parents while in the care of the parents as a foster child (42 USC 673(c)(1)(B) and 673(c)(2) as amended/added by Pub. L. No. 110-351). 6. Each State or local agency shall enter into adoption assistance agreements with the adoptive parents of children with special needs. The amount of the payments to be made shall be determined through agreement between the adoptive parents and the State or local agency administering the program (42 USC 673(a)1(A) and (a)(3)). Condition Of the sixty (60) samples selected for testing, we noted the following exceptions: 1. Three (3) samples where Section I Three Part Special Needs Determination or Barriers to Adoption of the AAP 4 form was not fully completed to support that the children have special needs. 2. Three (3) samples where documentation of the search for non-subsidy placement section of the AAP 4 form was not fully completed. 3. Three (3) samples where the AD 4320 AAP Agreements for two (2) were not fully completed and one (1) had an incorrect agreement date. 4. One (1) sample where the Federal Eligibility section of the AAP 4 form regarding the removal of a child from his or her parent(s) was not fully completed. 5. One (1) sample where there was no criminal record check, as well as child abuse and neglect registry check in the case file. Eligibility of AAP cases is determined when the cases are initiated. No redetermination is required, and eligible children can receive benefits until the age of 18 (or 21 if they meet specific requirements). Therefore, documentation of eligibility determination for some cases were prepared in the late 1990s or early 2000s, and the children in those cases could receive benefits in FY 2018-19 since they had not reached the age of 18 (or 21). Prior to 2010, there were many deficiencies in DCFS?s documentation of eligibility determination for the program. In 2010, DCFS implemented procedures to improve the accuracy and completeness of their documentation. Four (4) of the eight (8) samples noted in this finding are cases that were initiated prior to 2010. Cause 1. DCFS failed to fully complete a section of the AAP 4 form to support that the children have special needs due to human error and oversight. 2. DCFS failed to fully complete a section of the AAP 4 form to support that a search for non-subsidy placement was completed due to human error and oversight. 3. DCFS failed to fully complete the AD 4320 AAP Agreement and failed to document the correct agreement date due to human error and oversight. 4. DCFS failed to fully complete a section of the AAP 4 form to support that the child should be removed from his or her parent(s) due to human error and oversight. 5. The criminal record check and the child abuse and neglect registry check could not be located and DCFS management represented that they were most likely misplaced. Effect The lack of documentation and proper completion of the AAP 4 forms to support allowable activities and eligibility determinations results in questioned costs and noncompliance with 42 USC 673, 42 USC 671, and DCFS policies and procedures. Questioned Costs $145,714 (known questioned costs based on FY 18-19 assistance payments for the 8 samples) Context From a population of $124,414,750 of FY 18-19 assistance payments, eight (8) samples with total payments of $145,714 are noted with the following exceptions: 1. One (1) sample, totaling $42,156, did not fully complete the search for non- subsidy placement section of the AAP 4 form. 2. One (1) sample, totaling $29,964, a. Did not fully complete Section I Three Part Special Needs Determination or Barriers to Adoption of the AAP 4 form; b. Did not fully complete the search for non-subsidy placement section of the AAP 4 form; c. Did not fully complete the Federal Eligibility section of the AAP 4 form; and d. Did not have the DCFS representative signature on the AD 4320 AAP Agreement. 3. One (1) sample, totaling $12,384, did not document whether the AD 4320 AAP Agreement is the initial or amended agreement. 4. One (1) sample, totaling $18,180, did not have a criminal record check, as well as a child abuse and neglect registry check in the case file. 5. One (1) sample, totaling $18,732, documented an incorrect agreement date on the AD 4320 AAP Agreement. 6. One (1) sample, totaling $9,156, did not fully complete Section I Three Part Special Needs Determination or Barriers to Adoption of the AAP 4 form. 7. One (1) sample, totaling $12,108, did not fully complete the search for non- subsidy placement section of the AAP 4 form. 8. One (1) sample, totaling $3,034, did not fully complete Section I Three Part Special Needs Determination or Barriers to Adoption of the AAP 4 form. The sample was not a statistically valid sample. In addition, this is a repeat finding as indicated in the Status of Prior Years? Findings, as finding numbers 2018-005 and 2017- 007. Recommendation We recommend that DCFS performs the following procedures: 1. Continue to strengthen their review process to ensure completeness and accuracy on the AAP 4 ? Eligibility Certification and AD 4320 ? AAP Agreement. 2. Maintain adequate documentation for adoption case files.

Reference Number: 2019-003 Federal Program Title: Block Grants for Prevention and Treatment of Substance Abuse Federal Catalog Number: 93.959 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Health Care Services Federal Award Number and Year: 17-94136; Fiscal Year 18-19 Name of Department: Department of Public Health Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.331(a) Requirements for pass-through entities, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. (1) Federal Award Identification: (ii) Subrecipient?s unique entity identifier [generally the Data Universal Numbering System (DUNS) number] Condition During our review of subrecipient monitoring, we noted that the agreement between the Department of Public Health (DPH) and three (3) subrecipients did not contain the subrecipients? DUNS numbers. Cause Although subrecipients? DUNS numbers were included in some of the subawards, DPH was not aware that it is a compliance requirement for every subaward. Effect Failure to provide the required subaward information results in noncompliance with 2 CFR ?200.331(a). Questioned Costs No questioned costs were identified. Context Of the nine (9) subrecipients selected for testing, which totaled $2,824,988 from a population of $32,943,149, the subrecipients? DUNS numbers were not included in the subaward for three (3) subrecipients, totaling $853,297. The sample was not a statistically valid sample. Recommendation We recommend that DPH includes the subrecipients? DUNS numbers in the grant agreement for all subawards and communicate any changes in subsequent subaward modifications.

Reference Number: 2019-004 Federal Program Title: Temporary Assistance for Needy Families Federal Catalog Number: 93.558 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: California Department of Social Services Federal Award Number and Year: CFL No. 18/19-20; Fiscal Year 2018-19 Name of Department: Department of Children and Family Services Category of Finding: Allowable Costs/Cost Principles Criteria Title 2 U.S. Code of Federal Regulations (CFR) ?200.303 states that the non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition The Department of Children and Family Services (DCFS) has common internal controls over the payroll process for its federal programs. We selected seventy five (75) employees, two timesheets for each employee for a total of 150 timesheets, to test allowable costs and the internal controls over this category of compliance requirements. Twenty five (25) employees were selected from each of the three major programs below: 1. CFDA No. 93.558 Temporary Assistance for Needy Families (TANF) 2. CFDA No. 93.778 Medical Assistance Program 3. CFDA No. 93.659 Adoption Assistance During our review of the payroll transactions, two timesheets for one (1) employee, were not approved timely for the TANF program. (See Schedule of Findings and Questioned Costs for table.) Cause The timesheets were initially submitted electronically and placed on hold/rejected status since corrections needed to be made. Due to an oversight, the manual timesheet corrections were not submitted and approved until the transaction was selected for our review. Effect The late approval of employee timesheets results in noncompliance with 2 CFR ?200.303(a). Questioned Costs No questioned costs were identified. Context Of the one hundred and fifty (150) timesheets from seventy five (75) employees, totaling $471,722, selected from a population of $211,916,981, the timesheets for one (1) employee for the TANF program, totaling $7,681, were not approved timely. The sample was not a statistically valid sample. Recommendation We recommend that DCFS strengthens its review process to ensure all timesheets and manual corrections are approved in a timely manner.

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