El Paso, County of

Finding 2025-002 – Material Weakness: Eligibility – Control Finding ALN 93.658 - Title IV-E Foster Care Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Colorado Department of Human Services Criteria Or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), establishes requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. Condition: A secondary review of eligibility determinations did not occur in a timely manner during 2025. Cause: Management of the program did not implement an internal control process that functioned in a timely manner. Effect: The possibility exists that an individual was incorrectly determined to be eligible to receive benefits and this error was not identified and corrected in a timely manner. Questioned Costs: Not applicable Context: Our audit of the control processes around eligibility determination for the program determined no timely review over initial determination. Identification As A Repeat Finding: N/A Recommendation: We recommend that the County strengthen the processes within the internal control framework surrounding the review of eligibility determinations for this program. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding. See corrective action plan included in this report.

Significant Deficiency: Schedule of Expenditures of Federal Awards (SEFA) - Control Finding Criteria Or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance) provides guidance related to preparation and reporting of the SEFA. 2 CFR Section 200.100 identifies the required elements of the SEFA and 2 CFR Section 200.510 specifically requires that the SEFA include information on each federal award expended during the year. The County is required to prepare a complete and accurate SEFA and to have a system of internal controls, the design and operation of which allows management or employees in the normal course of performing their assigned functions to prevent, or detect and correct, errors on a timely basis. Condition: The SEFA was understated by a construction invoice that was not accrued as of year-end. A portion of those expenditures were included under a federal grant program. Cause: Management internal control process did not function properly in this instance to ensure an accurate SEFA. Effect: The possibility exists that errors within the SEFA could become material to the financial statements or result in an incorrect major program determination or incomplete testing of a major program. Questioned Costs: Not applicable Context: A sufficient review of the federal expenditure accruals did not occur so that an error to the SEFA report were not detected by management. Identification As A Repeat Finding: N/A Recommendation: We recommend that the County strengthen the processes within the internal control framework surrounding the review of year-end accruals for federal grant programs to ensure that all federal expenditures are complete and included in the correct period’s SEFA. Views Of Responsible Officials And Planned Corrective Action: The County agrees with the finding and has put together a correction action plan for the finding.