EIN: 956000934
UEI: CZTNNM6XJVJ3
Audited by: Eide Bailly LLP
Cognizant agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 30, 2026 (26 days from today).
What is a management decision? →As a result of our audit procedures, we noted that for three (3) out of three (3) first tier subawards tested there was no documented review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: We tested the entire population of three subawards obligations during the year. Repeat Finding from Prior Years: No Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Show full finding ▾Hide full finding ▴Program: COVID-19 CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: N/A - Direct Award Award No.: B20UW060501, B24UC060502 Award Year: 2021, 2025 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish, document, 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. Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: As a result of our audit procedures, we noted that for three (3) out of three (3) first tier subawards tested there was no documented review of the FFATA submissions by an individual independent of the preparation of the FFATA submissions. Cause: The County’s procedures did not include documenting the review and approval of the reports prior to submission. Effect: Ineffective controls over this area of compliance could result in reports that are inaccurate or incomplete being submitted or disclosed to the granting agency. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: We tested the entire population of three subawards obligations during the year. Repeat Finding from Prior Years: No Recommendation: We recommend the County revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
Reference Number 2025-002: Corrective Action Plan: Regarding internal controls over the FFATA (Federal Funding Accountability and Transparency Act) reporting, although no formal approval record could be provided, program staff reported that FFATA reports were verbally reviewed through one-on-one discussions. As recommended, the County will revise its internal FFATA reporting procedures to require that all FFATA submissions undergo a documented review and approval by an individual who is independent of the preparer. The procedures will be updated to require that the reviewer’s name, title, date of review, and confirmation of the reviewer’s approval be maintained in the program’s electronic records. The County will implement a standardized approval workflow—either through a designated electronic form, checklist, or approval routing mechanism—to ensure consistency across departments. Additionally, staff responsible for FFATA preparation and review will receive updated guidance and training on the new documentation requirements, The County will also evaluate opportunities to integrate this control into existing financial reporting and monitoring structures overseen by Housing and Community Development Services (HCDS) teams, to ensure consistent application of the updated approval requirements across reporting cycles. Anticipated Implementation Date: Updated procedures, workflow documentation, and staff training will be completed by June 30, 2026. Person Responsible: KELLY SALMONS, Deputy Director, Housing and Community Development Services
FAC accepted this audit on March 17, 2025 — management decision was due September 17, 2025.
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
FAC accepted this audit on August 15, 2022 — management decision was due February 15, 2023.
FAC accepted this audit on June 13, 2021 — management decision was due December 13, 2021.
The County?s Finance & General Government Group is responsible for monitoring its municipal subrecipeints and evaluating the subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring activities. However, the Finance & General Government Group did not conduct a formal risk assessment of each municipal subrecipient?s risk of noncompliance. Cause: To expedite the disbursement of these funds, the County did not receive applications, but instead awarded an amount to municipal governments within the County based on population. To receive the funds, each municipality provided an initial allocation plan to assess the eligibility of proposed expenditures; these plans had multiple levels of review and final approval was granted by Finance & General Government Group leadership. Municipal subrecipients were also contractually obligated to provide one interim and one final report as well as complete documentation of expenditures to further ensure eligibility and to continue grant monitoring throughout the term. While a formal risk assessment could include a questionnaire tailored to municipal governments and score sheet that categorizes subrecipients into tiered levels of risk types, the County viewed the Coronavirus Relief Fund (CRF) as emergency response funding intended to assist municipal governments with escalating pandemic costs. Furthermore and due to the somewhat new nature of the CRF where not all municipal governments received direct allocations or were eligible to receive allocations from the Federal government, the County sought to understand changing guidance from the Treasury Department. As a result, the Finance & General Government Group was not aware that a municipal subrecipient was subject to formal risk assessment requirements pursuant to the Uniform Guidance. The risk assessment performed by the County is briefly noted above and is detailed in each municipal subrecipient agreement. Effect: In the absence of a formal risk assessment process for determining appropriate monitoring procedures, sufficient and effective monitoring may not occur for those municipal subrecpients most at risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. However, the County did evaluate and monitor each municipal subrecipient, as noted above. Questioned Costs: Questioned costs were not identified. Context: Disbursement to municipal subrecipients during the fiscal year ended June 30, 2020, totaled to $23,653,988, representing approximately 22.2% of the respective program?s total federal expenditures. Recommendation: We recommend the Finance & General Government Group should develop and document a formal process for performing risk assessments over its municipal subrecipients in order to determine the frequency and extent of monitoring activities to be performed that is commensurate with the identified risks for each municipal subrecipient. Management?s Response and Corrective Action Plan: Management?s response is reported in ?Management?s Response and Corrective Action Plan? included in a separate section at the end of this report.
Show full finding ▾Hide full finding ▴Reference Number: 2020-001 Federal Program Title: Coronavirus Relief Fund Federal Catalog Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: None Federal Award Number and Year: SLT0151 (2020) Category of Finding: Subrecipient Monitoring Criteria: Title 2 ? Grants and Agreements. Subtitle A ? Office of Management and Budget Guidance for Grants and Agreements. Chapter II ? Office of Management and budget Guidance. Part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D ? Post Federal Award Requirements. Standards for Financial and Program Management. ?200.303 Internal Control (2 CFR 200.303): 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 status, 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 ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Subrecipient Monitoring and Management. ?200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (a) 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, which may include consideration of such factors as: (1) The subrecipient?s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has 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 Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: The County?s Finance & General Government Group is responsible for monitoring its municipal subrecipeints and evaluating the subrecipient?s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring activities. However, the Finance & General Government Group did not conduct a formal risk assessment of each municipal subrecipient?s risk of noncompliance. Cause: To expedite the disbursement of these funds, the County did not receive applications, but instead awarded an amount to municipal governments within the County based on population. To receive the funds, each municipality provided an initial allocation plan to assess the eligibility of proposed expenditures; these plans had multiple levels of review and final approval was granted by Finance & General Government Group leadership. Municipal subrecipients were also contractually obligated to provide one interim and one final report as well as complete documentation of expenditures to further ensure eligibility and to continue grant monitoring throughout the term. While a formal risk assessment could include a questionnaire tailored to municipal governments and score sheet that categorizes subrecipients into tiered levels of risk types, the County viewed the Coronavirus Relief Fund (CRF) as emergency response funding intended to assist municipal governments with escalating pandemic costs. Furthermore and due to the somewhat new nature of the CRF where not all municipal governments received direct allocations or were eligible to receive allocations from the Federal government, the County sought to understand changing guidance from the Treasury Department. As a result, the Finance & General Government Group was not aware that a municipal subrecipient was subject to formal risk assessment requirements pursuant to the Uniform Guidance. The risk assessment performed by the County is briefly noted above and is detailed in each municipal subrecipient agreement. Effect: In the absence of a formal risk assessment process for determining appropriate monitoring procedures, sufficient and effective monitoring may not occur for those municipal subrecpients most at risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. However, the County did evaluate and monitor each municipal subrecipient, as noted above. Questioned Costs: Questioned costs were not identified. Context: Disbursement to municipal subrecipients during the fiscal year ended June 30, 2020, totaled to $23,653,988, representing approximately 22.2% of the respective program?s total federal expenditures. Recommendation: We recommend the Finance & General Government Group should develop and document a formal process for performing risk assessments over its municipal subrecipients in order to determine the frequency and extent of monitoring activities to be performed that is commensurate with the identified risks for each municipal subrecipient. Management?s Response and Corrective Action Plan: Management?s response is reported in ?Management?s Response and Corrective Action Plan? included in a separate section at the end of this report.
Reference Number 2020-001: Corrective Action Plan: The Finance & General Government Group (FGG) agrees that it did not have a subrecipient risk assessment process in place for the municipal subrecipients, however FGG does not agree that it disregarded the risk associated with allocating CARES Act CRF Funds to the subrecipients. FGG took the following factors into consideration prior to releasing funds to subrecipients: 1) the CARES Act CRF allocations were intended to address a public health emergency quickly, 2) the subrecipients the County chose were local municipal governments (not small non-profits or businesses), and 3) the US Treasury made direct allocations to other cities based almost entirely on population, not risk level. FGG also mitigated risk by requiring initial proposals be aligned with CARES Act CRF guidance, then went through an approval process and a multi-phased reporting requirement. FGG took these additional precautions of reviewing and approving proposals, establishing written agreements, and requiring follow-up reporting to consider and account for any risk associated with allocating the CARES Act CRF Funds. No money would have been sent to a subrecipient that did not meet the initial proposal and written agreement requirements. Nonetheless, FGG will develop a formal program framework based on best practices which will include managing risk of non-compliance with subrecipients in order to determine the frequency and extent of monitoring activities for use with future federally funded programs. A more formal risk assessment would include a questionnaire tailored to the needs of municipal governments which FGG could use to produce a subrecipient score sheet. The risk assessment score sheet would categorize subrecipients into either high, medium, or low risk and impact the frequency and extent of monitoring activities. FGG will utilize best practices from the Government Finance Officers Association as well as practices in place in County departments such as the Office of Emergency Services. Anticipated Implementation Date: June 30, 2021 Person Responsible: Joshua Ramirez, Financial Policy & Planning Officer
FAC accepted this audit on February 25, 2020 — management decision was due August 25, 2020.
1. Section 3 Summary Report (annual performance report) was submitted on October 10, 2019, after the September 30, 2019 due date. 2. Semi-Annual Labor Standards Enforcement Report (biennial special report) for the six-months ended March 31, 2019 was submitted on April 9, 2019, after the April 8, 2019 due date. Cause: The program?s procedures did not consistently ensure that the required reports were submitted timely in accordance with the timelines in the Uniform Guidance and HUD standards. Effect: Failure to submit the Section 3 Summary Report and Semi-Annual Labor Standards Report timely results in noncompliance with the reporting requirements in the Uniform Guidance and HUD standards. Questioned Costs: Questioned costs were not identified. Recommendation: We recommend that the County strengthen their report submission process and procedures to ensure all required reports are submitted timely. When a report cannot be submitted by the due date, the County should request an extension from the funding agency and maintain a record of the approval. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Show full finding ▾Hide full finding ▴Federal Program Title: Community Development Block Grants/Entitlement Grants Federal Catalog Number: 14.218 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: None Federal Award Number and Year: B18UC060501 / 2018 Category of Finding: Reporting Criteria: In accordance with 2 CFR Part 200, Compliance Supplement, CFDA 14.218: Section L(2), HUD 60002, ?Section 3 Summary Report, Economic Opportunities for Low- and Very Low-Income Persons? (OMB No. 2529-0043) ? Each recipient that administers covered public and Indian housing assistance, regardless of the amount expended, and each recipient that administers covered housing and community development assistance in excess of $200,000 in a program year, must submit HUD 60002 information within 90 days of the fiscal year-end using the automated Section 3 Performance Evaluation and Registry System (SPEARS) (24 CFR sections 135.3(a)(1) and135.90). In addition, in accordance with the Department of Housing and Urban Development, Davis Bacon and Labor Standards, form HUD-4710, ?Semi-Annual Labor Standards Report - Local Contracting Agencies (HUD Programs)?, submissions are due on April 8 and October 8 for the six-months ended March 31 and September 30, respectively. Condition: 1. Section 3 Summary Report (annual performance report) was submitted on October 10, 2019, after the September 30, 2019 due date. 2. Semi-Annual Labor Standards Enforcement Report (biennial special report) for the six-months ended March 31, 2019 was submitted on April 9, 2019, after the April 8, 2019 due date. Cause: The program?s procedures did not consistently ensure that the required reports were submitted timely in accordance with the timelines in the Uniform Guidance and HUD standards. Effect: Failure to submit the Section 3 Summary Report and Semi-Annual Labor Standards Report timely results in noncompliance with the reporting requirements in the Uniform Guidance and HUD standards. Questioned Costs: Questioned costs were not identified. Recommendation: We recommend that the County strengthen their report submission process and procedures to ensure all required reports are submitted timely. When a report cannot be submitted by the due date, the County should request an extension from the funding agency and maintain a record of the approval. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Housing and Community Development Services (HCDS) will continue to ensure that the reports are submitted timely and any record of approved extension from the funding agency will be maintained. HCDS has updated the internal Master Calendar to include critical due dates including the Section 3, Davis Bacon, and REAC reporting dates. HCDS Program and fiscal managers will be responsible for ensuring the master calendar is followed throughout the year. Anticipated implementation date: April 30, 2020 Person responsible: Nicholas Martinez, Chief, Departmental Operations
The audited Financial Data Schedule (FDS) for the fiscal year ended June 30, 2018 was submitted on June 28, 2019, after the March 31, 2019 due date. Cause: The program?s procedures did not consistently ensure that the reports were submitted timely in accordance with the timelines in the Uniform Guidance. Effect: Failure to submit the audited FDS timely results in noncompliance with the reporting requirements in the grant agreement. Questioned Costs: Questioned costs were not identified. Recommendation: We recommend that the County strengthen their report submission process and procedures to ensure all required reports are submitted timely. When a report cannot be submitted by the due date, the County should request an extension from the funding agency and maintain a record of the approval. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Show full finding ▾Hide full finding ▴Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: None Federal Award Number and Year: CA108VO / 2018 Category of Finding: Reporting Criteria: Per 24 CFR ? 5.801(d)(1) - Uniform financial reporting standards, unaudited financial statements will be required 60 days after the PHA's fiscal year end, and audited financial statements will then be required no later than 9 months after the PHA's fiscal year end, in accordance with the Single Audit Act and 2 CFR part 200, subpart F. Condition: The audited Financial Data Schedule (FDS) for the fiscal year ended June 30, 2018 was submitted on June 28, 2019, after the March 31, 2019 due date. Cause: The program?s procedures did not consistently ensure that the reports were submitted timely in accordance with the timelines in the Uniform Guidance. Effect: Failure to submit the audited FDS timely results in noncompliance with the reporting requirements in the grant agreement. Questioned Costs: Questioned costs were not identified. Recommendation: We recommend that the County strengthen their report submission process and procedures to ensure all required reports are submitted timely. When a report cannot be submitted by the due date, the County should request an extension from the funding agency and maintain a record of the approval. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
HCDS will continue to ensure that the reports are submitted timely and any record of approved extension from the funding agency will be maintained. HCDS has updated the internal Master Calendar to include critical due dates including the Section 3, Davis Bacon, and REAC reporting dates. HCDS Program and fiscal managers will be responsible for ensuring the master calendar is followed throughout the year. Anticipated implementation date: April 30, 2020 Person responsible: Nicholas Martinez, Chief, Departmental Operations
The refrigerator category?s rate changed more than 10 percent for the fiscal year 2019 from the last time the utility allowance was revised for fiscal year 2018, and the submitted utility allowance schedule for fiscal year 2019 was not adjusted accordingly. Cause: The manually inputted information for the submitted utility allowance schedule was entered incorrectly. Effect: Failure to adjust the utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised, results in noncompliance with the special tests and provisions requirements in the Uniform Guidance. Questioned Costs: Questioned costs were not identified. Recommendation: We recommend that the County strengthen their internal control process by having a 2nd reviewer prior to submission to HUD, or implementing an automated process to enter values into the schedule, thereby preventing future manual input errors. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
Show full finding ▾Hide full finding ▴Federal Program Title: Section 8 Housing Choice Vouchers Federal Catalog Number: 14.871 Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entity: None Federal Award Number and Year: CA108VO / 2018 Category of Finding: Special Tests/Provisions ? Utility Allowance Schedule Criteria: In accordance with 2 CFR Part 200 Compliance Supplement, CFDA 14.871: The PHA must maintain an up-to-date utility allowance schedule. The PHA must review utility rate data for each utility category each year and must adjust its utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised (24 CFR section 982.517). Condition: The refrigerator category?s rate changed more than 10 percent for the fiscal year 2019 from the last time the utility allowance was revised for fiscal year 2018, and the submitted utility allowance schedule for fiscal year 2019 was not adjusted accordingly. Cause: The manually inputted information for the submitted utility allowance schedule was entered incorrectly. Effect: Failure to adjust the utility allowance schedule if there has been a rate change of 10 percent or more for a utility category or fuel type since the last time the utility allowance schedule was revised, results in noncompliance with the special tests and provisions requirements in the Uniform Guidance. Questioned Costs: Questioned costs were not identified. Recommendation: We recommend that the County strengthen their internal control process by having a 2nd reviewer prior to submission to HUD, or implementing an automated process to enter values into the schedule, thereby preventing future manual input errors. Management?s Response and Corrective Action Plan: Refer to the separate corrective action plan.
HCDS will review and update its procedures and templates as follows: a) Add detailed instructions outlining the necessary steps of determining the calculations and inputting the data into the PDF fillable HUD file form. b) Implement review by two Analyst staff to ensure proper figures are transferred into PDF c) Implement a sign-off process for both Analysts and Program Coordinator d) Enhance our Excel spreadsheet to include last year?s data, percent change, and conditional formatting to alert us when the change is greater than 10% Anticipated implementation date: April 30, 2020 Person responsible: Nicholas Martinez, Chief, Departmental Operations
FAC accepted this audit on February 21, 2019 — management decision was due August 21, 2019.
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Show full finding ▾Hide full finding ▴FAC accepted this audit on February 18, 2018 — management decision was due August 18, 2018.
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FAC accepted this audit on October 30, 2016 — management decision was due April 30, 2017.
FAC accepted this audit on February 16, 2017 — management decision was due August 16, 2017.
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