Mesa County, Colorado

Criteria: Per 2 CFR 200.332, Mesa County is responsible for informing subrecipients of the Federal award identifiers including but not limited to award date, period of performance and Federal awarding agency and Assistance Listing Number and title. Mesa County is required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. In addition, the County should also verify that the subrecipient is audited as required by Subpart F - Audit Requirement under the Uniform Guidance. The monitoring policy should include an initial valuation of risk of noncompliance to determine the appropriate level of monitoring required related to the subaward as well as appropriate awarding documentation. Condition: During our testing, we evaluated the procedures for evaluating subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. We noted the following: • For two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient’s risk of noncompliance was not documented. Cause: The County did not adhere to their established policies and procedures relating to risk assessment when a subrecipient contract is awarded. Effect: The County’s policies were not consistently followed requiring compliance with the Subrecipient monitoring requirements in 2 CFR 200.332. Additionally, the County’s control policies were not consistently followed. Questioned Costs: None to report. Context/Sampling: The population of two (2) subrecipients were selected for subrecipient monitoring testing for the direct award from the US Department of Treasury. The total population across the program, including sub-awards from the State of Colorado was 2 subrecipients. Repeat Finding from Prior Years: Yes. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Agree

Criteria: The Federal requirement related to processing of an application requires the State to provide notice of its decision concerning eligibility and provide timely and adequate notice of the basis for denial or termination of assistance (42 USC 1320c-7(d)). According to the Colorado Department of Health Care Policy and Financing (HCPF), processing standards 8.100.3.D, the County is required to process an initial application for any program not requiring a disability determination no later than 45 days following receipt of application. In addition, federal requirements as described at 42 CFR 435.139 and 435.350 requires state medical assistance programs to provide medical coverage for care and services that are necessary to treat a medical emergency for individuals who do not meet immigration or citizenship requirements for Medicaid through Health First Colorado (Colorado’s Medicaid Program). Per the Colorado Department of Health Care policy memo number HCPF PM 22-006, Emergency Medicaid only covers the treatment of emergency medical conditions that a physician determines (confirms) to be life- or limb-threatening and is coded as an emergency. Members who submit an initial application and are determined eligible for Emergency Medicaid Services will receive these services for up to a 12-month period or until the case is redetermined at the end of their renewal period. A 12-month period does not guarantee paid services: all services must be considered emergency treatment by a physician to be covered. Condition: We tested eligibility determination and controls over this process for sixty case files. We noted the following in our testing: • Six instances of non-compliance in which the County did not complete the eligibility determination and approve/deny the case within 45 days and no notice of action was sent to the client within the required timeframe. • One instance of non-compliance in which the County did not identify that the participant no longer qualified for Emergency Medicaid Services and continued to provide benefits to the participant. Cause: Due to the County’s ineffective monitoring, eligibility determinations were not completed in a timely manner and within the 45-day deadline. Effect: Failure to process applications timely could result in participants that are delayed approval of Medicaid services. Questioned Costs: None to report. Context/Sampling: A nonstatistical sample of 60 participants were selected for eligibility testing. Repeat Finding from Prior Years: Yes, 2023-008 Recommendation: We recommend the County utilize available COGNOS reports to determine which cases are nearing the exceeding processing guidelines and which cases are life- or limb-threatening related and ensure re-determinations are completed accurately. Views of Responsible Officials: Agree

Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. 2 CFR section Appendix II to Part 200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in addition to other provisions required by the Federal agency or non-Federal entity, all contracts made by the non-Federal entity under the Federal award must contain certain provisions, as applicable. Condition: The following information was not provided at the time of the contract award for one (1) contract selected for testing: •Byrd Anti-Lobbying Amendment •Clean Air Act and Federal Water Pollution Control Act •Davis-Bacon Act Cause: The County’s procedures did not consistently ensure that the applicable required provisions were communicated to contractors. Effect: The County did not identify the applicable required provisions of the contract to the contractors at the time of the contract award resulting in a finding. Questioned Costs: None to report Context/Sampling: One (1) contract selected for procurement and suspension and debarment testing for the direct award from the US Department of Treasury. The total population across the program, including sub-awards from the State of Colorado was 4 procurement contracts. Repeat Finding from Prior Year(s): No Recommendation: We recommend the County modify and strengthen its current policies and procedures to ensure that all applicable required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200. Views of Responsible Officials: Agree

Criteria: The Uniform Guidance, Section 200.303 Internal Controls, requires that the non-Federal entity must establish and maintain documentation of effective internal controls over Federal awards that provide reasonable assurance that awards are being managed in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition: During testing there were four reports that we were unable to test the reporting requirements as the County did not retain evidence of the report. Cause: The County failed to ensure the internal controls surrounding compliance over the program’s reporting criteria was met. Effect: The compliance requirement for reporting for the quarterly reports related to the sub-award received from the Colorado Department of Labor was unable to be tested. Questioned Costs: None to report. Context/Sampling: We selected 13 reports out of 23 required to be submitted with the various awards under this ALN. We were unable to test four reports. Repeat Finding from Prior Years: No. Recommendation: We recommend the County ensure review and approval controls are in place to ensure all required reports are submitted timely. Views of Responsible Officials: Agree

Criteria: Per 2 CFR 200.332, Mesa County is responsible for informing subrecipients of the Federal award identifiers including but not limited to award date, period of performance and Federal awarding agency and Assistance Listing Number and title. Mesa County is required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. In addition, the County should also verify that the subrecipient is audited as required by Subpart F - Audit Requirement under the Uniform Guidance. The monitoring policy should include an initial valuation of risk of noncompliance to determine the appropriate level of monitoring required related to the subaward as well as appropriate awarding documentation. Condition: During our testing, we evaluated the procedures for evaluating subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward. We noted the following: • For two (2) of two (2) subrecipients selected, the required evaluation of the subrecipient’s risk of noncompliance was not documented. Cause: The County did not adhere to their established policies and procedures relating to risk assessment when a subrecipient contract is awarded. Effect: The County’s policies were not consistently followed requiring compliance with the Subrecipient monitoring requirements in 2 CFR 200.332. Additionally, the County’s control policies were not consistently followed. Questioned Costs: None to report. Context/Sampling: The population of two (2) subrecipients were selected for subrecipient monitoring testing for the direct award from the US Department of Treasury. The total population across the program, including sub-awards from the State of Colorado was 2 subrecipients. Repeat Finding from Prior Years: Yes. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: Agree

Criteria: The Uniform Guidance, Section 200.303 Internal Controls, requires that non-Federal entities must establish and maintain documentation of effective internal controls over Federal awards that provide reasonable assurance that awards are being managed in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition: We tested 19 eligibility files for IV-E eligibility determinations and noted there was no evidence of internal controls over the determination of IV-E eligibility for all of the files tested. Cause: The County did not have the appropriate controls in place to comply with the Uniform Guidance Section 200.303 over Internal Controls over compliance with Federal awards. Effect: The County is not in compliance with the Uniform Guidance requirements of internal controls. Questioned Costs: None to report. Context/Sampling: A nonstatistical sample of 19 IV-E children files out of 91 were selected for eligibility testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the County implement controls which include a review of all eligibility files for IV-E determinations. Views of Responsible Officials: Agree

Criteria: The Uniform Guidance, Section 200.303 Internal Controls, requires that non-Federal entities must establish and maintain documentation of effective internal controls over Federal awards that provide reasonable assurance that awards are being managed in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Condition: We tested 6 eligibility files for eligibility determinations and noted there was no evidence of internal controls over the determination of eligibility families for all of the files tested. Cause: The County did not have the appropriate controls in place to comply with the Uniform Guidance Section 200.303 over Internal Controls over compliance with Federal awards. Effect: The County is not in compliance with the Uniform Guidance requirements of internal controls. Questioned Costs: None to report. Context/Sampling: A nonstatistical sample of 6 files out of 27 were selected for eligibility testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the County implement controls which include a review of all eligibility files for family determinations. Views of Responsible Officials: Agree

Criteria: The Federal requirement related to processing of an application requires the State to provide notice of its decision concerning eligibility and provide timely and adequate notice of the basis for denial or termination of assistance (42 USC 1320c-7(d)). According to the Colorado Department of Health Care Policy and Financing (HCPF), processing standards 8.100.3.D, the County is required to process an initial application for any program not requiring a disability determination no later than 45 days following receipt of application. Condition: We tested eligibility determination and controls over this process for sixty case files. We noted the following in our testing: •Nine instances of non-compliance in which the County did not complete the eligibilitydetermination and approve/deny the case within 45 days and no notice of action wassent to the client within the required timeframe. Cause: Due to the County’s ineffective monitoring, eligibility determinations were not completed in a timely manner and within the 45-day deadline. Effect: Failure to process applications timely could result in participants that are delayed approval of Medicaid services. Questioned Costs: None to report. Context/Sampling: A nonstatistical sample of 60 participants were selected for eligibility testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the County utilize available COGNOS reports to determine which cases are nearing the exceeding processing guidelines. Views of Responsible Officials: Agree