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DEPARTMENT OF THE TREASURY
W ASHINGTON, D.C. 20220
OFFICE OF
INSPECTOR GENERAL
September 20, 2024
MEMORANDUM FOR JESSICA MILANO, CHIEF PROGRAM OFFICER, OFFICE OF
CAPITAL ACCESS, DEPARTMENT OF THE TREASURY
FROM: Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT: Desk Review of Bergen County, New Jersey’s Use of
Coronavirus Relief Fund Proceeds
(OIG-CA-24-028)
Please find the attached desk review memorandum 1 on Bergen County, New
Jersey’s (Bergen County) use of Coronavirus Relief Fund (CRF) proceeds. The CRF
is authorized under Title VI of the Social Security Act, as amended by Title V,
Division A of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
Under a contract monitored by our office, Castro & Company, LLC (Castro), a
certified independent public accounting firm, performed the desk review. Castro
performed the desk review in accordance with the Council of the Inspectors
General on Integrity and Efficiency Quality Standards for Federal Offices of
Inspector General standards of independence, due professional care, and quality
assurance.
In its desk review, Castro personnel reviewed documentation for a non-statistical
selection of 20 transactions reported in the quarterly Financial Progress Reports
(FPR) and identified unsupported questioned costs of $57,000 (see attached
schedule of monetary benefits). 2
1
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) assigned the Department of
the Treasury Office of Inspector General with responsibility for compliance monitoring and
oversight of the receipt, disbursement, and use of Coronavirus Relief Fund (CRF) payments. The
purpose of the desk review is to perform monitoring procedures of the prime recipient’s receipt,
disbursement, and use of CRF proceeds as reported in the grants portal on a quarterly basis.
2
Questioned costs consist of unsupported payroll expenses related to extra duty pay awarded to
county employees who were unable to use compensatory time off earned for the extra hours spent
working on COVID-19 related tasks.
Page 2
Castro determined that the expenditures related to Contracts greater than or equal
to $50,000 and Transfers greater than or equal to $50,000 3 complied with the
CARES Act and Department of the Treasury’s (Treasury) Guidance. Castro also
found that Direct Payments greater than or equal to $50,000 complied with the
CARES Act but did not comply with Treasury’s Guidance. Additionally, Castro
determined Aggregate Reporting less than $50,000 4 did not comply with CARES
Act and Treasury’s guidance. Castro determined that Bergen County’s risk of
unallowable use of funds is moderate.
Castro recommends that Treasury Office of Inspector General (OIG) follow-up with
Bergen County’s management to confirm if the transactions noted as unsupported
expenditures within Aggregate Reporting less than $50,000 can be supported. If
support is not provided, Treasury OIG should recoup the funds or request Bergen
County management provide support for replacement expenses, not previously
charged, that were eligible during the CRF period of performance. Further, based
on Bergen County’s responsiveness to Treasury OIG’s requests and its ability to
provide sufficient documentation and/or replace unsupported transactions
charged to CRF with valid expenditures, Castro recommends Treasury OIG
determine the feasibility of conducting an audit for the Aggregate Reporting less
than $50,000 payment type.
Treasury OIG and Castro met with Bergen County management to discuss the
questioned costs. Bergen County management stated they would provide
additional documentation to Treasury OIG to support the questioned costs.
In connection with our contract with Castro, we reviewed Castro’s desk review
memorandum and related documentation and inquired of its representatives. Our
review, as differentiated from an audit performed in accordance with generally
accepted government auditing standards, was not intended to enable us to
express an opinion on Bergen County’s use of CRF proceeds. Castro is
responsible for the attached desk review memorandum and the conclusions
expressed therein. Our review found no instances in which Castro did not comply
in all material respects with Quality Standards for Federal Offices of Inspectors
General.
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. If you have any questions or require further information,
3
A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
4
Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in the
grants portal. Transactions less than $50,000 can be reported as an aggregate lump-sum amount
by type (contracts, grants, loans, direct payments, and transfers to other government entities).
Page 3
please contact me at (202) 486-1420, or a member of your staff may contact Lisa
DeAngelis, Deputy Assistant Inspector General for Audit, at (202) 487-8371.
cc: Melissa Howard, Bergen County Treasurer
Michelle. A. Dickerman, Deputy Assistant General Counsel, Department of
the Treasury
Danielle Christensen, Deputy Chief Program Officer, Office of Capital
Access, Department of the Treasury
Wayne Ference, Partner, Castro & Company, LLC
Page 4
Attachment
Schedule of Monetary Benefits
According to the Code of Federal Regulations, 5 a questioned cost is a cost that is
questioned due to a finding:
(a) which resulted from a violation or possible violation of a statute,
regulation, or the terms and conditions of a Federal award, including for
funds used to match Federal funds;
(b) where the costs, at the time of the review, are not supported by
adequate documentation; or
(c) where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Questioned costs are to be recorded in Treasury’s Joint Audit Management
Enterprise System (JAMES). 6 The amount will also be included in the OIG
Semiannual Report to Congress. It is Treasury management's responsibility to
report to Congress on the status of the agreed to recommendations with
monetary benefits in accordance with 5 USC 405.
Recommendation Questioned Costs
Recommendation No. 1 $ 57,000
The questioned cost represents amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $57,000 is
Bergen County’s expenditures reported in the grant-reporting portal that lacked
supporting documentation.
5
2 CFR § 200.84 – Questioned Cost
6
JAMES is Treasury’s audit recommendation tracking system.
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
Desk Review of Bergen County, New Jersey
September 20, 2024
OIG-CA-24-028
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM: Wayne Ference
Partner, Castro & Company, LLC
SUBJECT: Desk Review of Bergen County, New Jersey
On September 13, 2023, we initiated a desk review of Bergen County, New
Jersey’s (Bergen County) use of the Coronavirus Relief Fund (CRF) authorized
under Title VI of the Social Security Act, as amended by Title V, Division A of the
Coronavirus Aid, Relief, and Economic Security Act (CARES Act). 1 The objective of
our desk review was to evaluate Bergen County’s documentation supporting its
uses of CRF proceeds as reported in the GrantSolutions 2 portal and to assess the
risk of unallowable use of funds. The scope of our desk review was limited to
obligation and expenditure data for the period of March 1, 2020 through
September 30, 2023, as reported in the GrantSolutions portal.
As part of our desk review, we performed the following:
1) reviewed Bergen County’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal through September 30, 2023;
2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance as published in the Federal Register on January 15, 2021; 3
3) reviewed Treasury’s Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping; 4
1
P.L. 116-136 (March 27, 2020).
2
GrantSolutions, a grant and program management Federal shared service provider under the
United States (U.S.) Department of Health and Human Services, developed a customized and user-
friendly reporting solution to capture the use of CRF payments from prime recipients.
3
Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
4
Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021.
1
Desk Review of Bergen County, New Jersey
4) reviewed Treasury OIG’s monitoring checklists5 of Bergen County’s
quarterly FPR submissions for reporting deficiencies;
5) reviewed other audit reports issued, such as Single Audit Act reports 6, and
those issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may
pose risk or impact Bergen County’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations, the Council of the
Inspectors General on Integrity and Efficiency Pandemic Response
Accountability Committee, 7 and Treasury OIG Office of Counsel input on
issues that may pose risk or impact Bergen County’s uses of CRF proceeds;
7) interviewed key personnel responsible for preparing and certifying Bergen
County’s GrantSolutions portal quarterly FPR submissions, as well as
officials responsible for obligating and expending CRF proceeds;
8) made a non-statistical selection of Contracts, Transfers, 8 Direct Payments,
and Aggregate Reporting 9 data identified through GrantSolutions
reporting; and
9) evaluated documentation and records used to support Bergen County’s
quarterly FPRs.
5
The checklists were used by Treasury OIG personnel to monitor the progress of prime recipient
reporting in the GrantSolutions portal. GrantSolutions quarterly submission reviews were
designed to identify material omissions and significant errors, and where necessary, included
procedures for notifying prime recipients of misreported data for timely correction. Treasury OIG
followed the CRF Prime Recipient Quarterly GrantSolutions Submissions Monitoring and Review
Procedures Guide, OIG-CA-20-029R to monitor the prime recipients on a quarterly basis.
6
P. L. 104-156 (July 5, 1996) The Single Audit Act of 1984, as amended in 1996, requires entities
who receive federal funds in excess of $750,000 to undergo an annual audit of those Federal funds.
The act was enacted for the purpose of promoting sound financial management, including
effective internal controls, with respect to Federal awards administered by non-Federal entities and
to establish uniform requirements for audits. This prime recipient was subject to those audit
requirements, and Castro reviewed applicable prior year single audit reports as part of our desk
review risk assessment procedures.
7
Section 15010 of P.L. 116-136, the CARES Act, established the Pandemic Response Accountability
Committee within the Council of the Inspectors General on Integrity and Efficiency to promote
transparency and conduct and support oversight of covered funds (see Footnote 14 for a definition
of covered funds) and the coronavirus response to (1) prevent and detect fraud, waste, abuse, and
mismanagement; and (2) mitigate major risks that cut across program and agency boundaries.
8
A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
9
Prime recipients were required to report CRF transactions greater than or equal to $50,000 in
detail in the GrantSolutions portal. Transactions less than $50,000 could be reported as an
aggregate lump-sum amount by type (contracts, grants, loans, direct payments, and transfers to
other government entities).
2
Desk Review of Bergen County, New Jersey
Based on our review of Bergen County’s documentation supporting the uses of its
CRF proceeds as reported in the GrantSolutions portal, we determined that the
expenditures related to the Contracts greater than or equal to $50,000 and
Transfers greater than or equal to $50,000 payment types complied with the
CARES Act and Treasury’s Guidance. We also found that the Direct Payments
greater than or equal to $50,000 payment type complied with the CARES Act but
did not comply with Treasury’s Guidance. Additionally, we found that the
Aggregate Reporting less than $50,000 payment type did not comply with the
CARES Act and Treasury’s Guidance. We identified unsupported questioned costs
of $57,000 within the Aggregate Reporting less than $50,000 payment type. We
also determined Bergen County’s risk of unallowable use of funds is moderate.
Castro recommends that Treasury OIG follow up with Bergen County
management to confirm if the transactions noted as unsupported expenditures
within Aggregate Reporting less than $50,000 can be supported. If support is not
provided, Treasury OIG should recoup the funds or request that Bergen County
management provide support for replacement expenses, not previously charged,
that were eligible during the CRF period of performance. Further, based on Bergen
County’s responsiveness to Treasury OIG’s requests and its ability to provide
sufficient documentation and/or replace unsupported transactions charged to the
CRF with valid expenditures, we recommend Treasury OIG determine the
feasibility of conducting an audit for the Aggregate Reporting less than $50,000
payment type.
Non-Statistical Transaction Selection Methodology
Treasury issued a $162,662,060 CRF payment to Bergen County. As of
September 30, 2023, Bergen County’s cumulative obligations and expenditures
were both $162,483,300. Bergen County returned a total of $178,760 in CRF
proceeds to Treasury. Bergen County’s cumulative obligations and expenditures
by payment type are summarized below.
Cumulative Cumulative
Payment Type Obligations Expenditures
Contracts >= $50,000 $ 36,483,896 $ 36,483,896
Grants >= $50,000 $ - $ -
Loans >= $50,000 $ - $ -
Transfers >= $50,000 $ 44,071,742 $ 44,071,742
Direct Payments >= $50,000 $ 1,656,206 $ 1,656,206
Aggregate Reporting < $50,000 $ 80,271,456 $ 80,271,456
Aggregate Payments to
Individuals (in any amount) $ - $ -
Totals $ 162,483,300 $ 162,483,300
3
Desk Review of Bergen County, New Jersey
Castro made a non-statistical selection of Contracts greater than or equal
to $50,000, Transfers greater than or equal to $50,000, Direct Payments greater
than or equal to $50,000, and Aggregate Reporting less than $50,000 payment
types. Selections were made using auditor judgment based on information and
risks identified in reviewing audit reports, the GrantSolutions portal reporting
anomalies 10 identified by the Treasury OIG CRF monitoring team, and review of
Bergen County’s FPR submissions. Bergen County did not obligate or expend CRF
proceeds to the Grants greater than or equal to $50,000, Loans greater than or
equal to $50,000, and Aggregate Payments to Individuals 11 payment types;
therefore, we did not make a selection of transactions from these payment types.
The number of transactions (20) we selected to test was based on Bergen
County’s total CRF award amount and our overall risk assessment of Bergen
County. To allocate the number of transactions (20) by payment type (Contracts
greater than or equal to $50,000, Transfers greater than or equal to $50,000, Direct
Payments greater than or equal to $50,000, and Aggregate Reporting less than
$50,000), we compared the payment type dollar amounts as a percentage of
cumulative expenditures as of September 30, 2023. The transactions selected for
testing were not selected statistically, and therefore results could not be
extrapolated to the total universe of transactions.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States and certain local
governments; the District of Columbia and U.S. Territories, including the
Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa,
and the Commonwealth of the Northern Mariana Islands; and Tribal governments
(collectively referred to as “prime recipients”). Treasury issued a $162,662,060
CRF payment to Bergen County. The CARES Act stipulates that a prime recipient
may only use the funds to cover costs that—
(1) were necessary expenditures incurred due to the public health
emergency with respect to the coronavirus disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
10
Treasury OIG had a pre-defined list of risk indicators that were triggered based on data
submitted by prime recipients in the FPR submissions that met certain criteria. Castro reviewed
these results provided by Treasury OIG for the prime recipient.
11
Obligations and expenditures for payments made to individuals, regardless of amount, were
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
4
Desk Review of Bergen County, New Jersey
(3) were incurred during the covered period between March 1, 2020 and
December 31, 2021. 12
Section 15011 of the CARES Act required each covered recipient 13 to submit to
Treasury and the Pandemic Response Accountability Committee, no later than 10
days after the end of each calendar quarter, a report that contained (1) the total
amount of large covered funds 14,15 received from Treasury; (2) the amount of large
covered funds received that were expended or obligated for each project or
activity; (3) a detailed list of all projects or activities for which large covered funds
were expended or obligated; and (4) detailed information on any level of sub-
contracts or sub-grants awarded by the covered recipient or its sub-recipients.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also has the authority to recoup funds in the event that it is
determined a recipient failed to comply with requirements of subsection 601(d) of
the Social Security Act, as amended, (42 U.S.C. 801(d)).
Desk Review Results
Financial Progress Reports
We reviewed Bergen County’s quarterly FPRs through September 30, 2023, and
found that Bergen County failed to submit quarterly FPRs in the GrantSolutions
portal for the reporting period ending June 30, 2021, and the reporting periods
ending September 30, 2022 through June 30, 2023, resulting in non-compliance
with Treasury OIG’s reporting requirements for those reporting periods. Bergen
County fully expended their total CRF proceeds as of December 31, 2021;
however, Bergen County returned $178,760 in its September 30, 2023
GrantSolutions portal submission.
12
P.L. 116-260 (December 27, 2020). The covered period end date of the CRF was extended through
December 31, 2021 by the Consolidated Appropriations Act, 2021. The covered period end date for
tribal entities was further extended to December 31, 2022 by the State, Local, Tribal, and Territorial
Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act, Division LL of the Consolidated
Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136 Stat. 4459.
13
Section 15011 of P.L. 116-136, the CARES Act, defined a covered recipient as any entity that
received large covered funds and included any State, the District of Columbia, and any territory or
possession of the United States.
14
Section 15010 of P.L. 116-136, the CARES Act, defined covered funds as any funds, including
loans, that were made available in any form to any non-Federal entity, not including an individual,
under Public Laws 116-123, 127, and 136, as well as any other law which primarily made
appropriations for Coronavirus response and related activities.
15
Section 15011 of P.L. 116-136 defined large covered funds as covered funds that amounted to
more than $150,000.
5
Desk Review of Bergen County, New Jersey
Summary of Testing Results
We found that the Contracts greater than or equal to $50,000 and Transfers
greater than or equal to $50,000 payment types complied with the CARES Act and
Treasury’s Guidance. We also found that the Direct Payments greater than or
equal to $50,000 payment type complied with the CARES Act but did not comply
with Treasury’s Guidance. Additionally, we found that the Aggregate Reporting
less than $50,000 payment type did not comply with the CARES Act and
Treasury’s Guidance because we were unable to determine if all tested
expenditures were necessary due to the COVID-19 public health emergency, were
not accounted for in the budget most recently approved as of March 27, 2020, and
were incurred during the covered period. The transactions selected for testing
were not selected statistically, and therefore results could not be extrapolated to
the total universe of transactions.
Within the table below, we have included a summary of unsupported and
ineligible expenditures identified as questioned costs, which did not comply with
the CARES Act and Treasury’s Guidance. See the Desk Review Results section
below this table for a detailed discussion of questioned costs and other issues
identified throughout the course of our desk review.
6
Desk Review of Bergen County, New Jersey
Summary of Expenditures Testing and Recommended Results
As of September 30, 2023
Cumulative
Expenditure Cumulative Unsupported Ineligible Total
Population Expenditure Questioned Questioned Questioned
Payment Type
Amount Tested Amount Costs Costs Costs
Contracts >=
$50,000 $ 36,483,896 $ 4,584,890 $ - $ - $ -
Grants >= $50,000
$ - $ - $ - $ - $ -
Loans >= $50,000
$ - $ - $ - $ - $ -
Transfers >=
$50,000 $ 44,071,742 $ 20,274,460 $ - $ - $ -
Direct Payments
>= $50,000 $ 1,656,206 $ 1,656,206 $ - $ - $ -
Aggregate
Reporting <
$50,000 $ 80,271,456 $ 393,501 $ 57,000 $ - $ 57,000
Aggregate
Payments to
Individuals (in any
amount) $ - $ - $ - $ - $ -
Totals $ 162,483,300 $ 26,909,057 $ 57,000 $ - $ 57,000
Contracts Greater Than or Equal to $50,000
We determined Bergen County’s Contracts greater than or equal to $50,000
complied with the CARES Act and Treasury’s Guidance. We tested four contracts
totaling $4,584,890 and identified no exceptions. The contracts tested included
expenditures for the purchase of upgrading the heating, ventilation, and air
conditioning systems in Bergen County’s government facilities in response to
COVID-19; improving private fiber networks to ensure sufficient bandwidth was
accessible for Bergen County employees working remotely during the pandemic;
and a contract with a credit union for processing and reviewing applications for
pandemic related small business grants.
Transfers to Other Government Entities Greater Than or Equal to $50,000
We determined Bergen County’s Transfers to Other Government Entities greater
than or equal to $50,000 complied with the CARES Act and Treasury’s Guidance.
We tested five transfers totaling $20,274,460 and identified no exceptions. The
transfers tested included expenditures for the reimbursement of payroll costs for
medical facilities and public health and safety personnel; purchase of computer
equipment for distance learning; purchase of medical equipment for
municipalities’ ambulances; and the purchase of tablets to promote remote
7
Desk Review of Bergen County, New Jersey
learning for Bergen County’s technical school’s student population due to
pandemic related school closures.
Direct Payments Greater Than or Equal to $50,000
We determined Bergen County’s Direct Payments greater than or equal to $50,000
complied with the CARES Act but did not comply with Treasury’s Guidance. We
tested one direct payment totaling $1,656,206 and identified no exceptions. The
direct payment tested included expenditures for the purchase of COVID-19 health
insurance claims overages for Bergen County employees.
However, we did note a GrantSolutions portal reporting error related to the one
Direct Payment transaction we tested, which did not impact the eligibility or
allowability of the CRF proceeds claimed for reimbursement. Bergen County made
a payment to an outside entity using general funds, which demonstrated an arms-
length transaction. After the payment was made, Bergen County reviewed the
transaction details and determined the expenditure was eligible for
reimbursement with CRF proceeds. In the GrantSolutions portal, Bergen County
incorrectly reported the reimbursement to Bergen County and not the outside
entity that was ultimately paid. As a result of listing Bergen County as the payee,
we identified this as a reporting error that did not comply with Treasury’s
Guidance. 16
16
Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently
Asked Questions Related to Reporting and Recordkeeping (Revised) OIG-CA-20-028R Section #5
states, “If the prime recipient distributes funds to an agency or department within the prime
recipient’s government, is the agency or department considered the prime recipient or a sub-
recipient when funds obligated are $50,000 or more? The agency or department is considered part
of the prime recipient as they are all part of the same legal entity that received a direct CRF
payment from Treasury. Obligations and expenditures that the agency or department incurs with
the CRF proceeds must be collected by and reported in the GrantSolutions portal by the prime
recipient as if they were obligated or expended by the prime recipient.”
8
Desk Review of Bergen County, New Jersey
Aggregate Reporting Less Than $50,000
We determined Bergen County’s Aggregate Reporting less than $50,000 did not
comply with the CARES Act and Treasury’s Guidance. We tested 10 aggregate
reporting transactions totaling $393,501 and identified five exceptions, resulting in
unsupported questioned costs totaling $57,000. The aggregate reporting
transactions tested included expenditures for the purchase of medical supplies;
improving the fiber optic network to enhance remote learning capabilities for
schools due to pandemic related school closures; purchase to enhance telework
capabilities; reimbursement of payroll costs for public health and safety
employees due to pandemic related office closures; reimbursement of payroll
costs for substantially dedicated 17 personnel; reimbursement of sick pay for
county employees performing tasks in response to COVID-19; and COVID-19 extra
duty pay for unused compensatory time off.
For five of the transactions tested, Bergen County’s management was unable to
provide adequate supporting documentation to determine if the expenditures
were eligible. Specifically, Bergen County used CRF proceeds to cover extra duty
pay awarded to county employees who were unable to use compensatory time off
earned for the extra hours spent working on COVID-19 related tasks.
Based on the support reviewed, Bergen County was unable to justify how the
extra duty pay was assigned to each employee. Bergen County confirmed the
extra duty pay expenditures were distributed by lump sum payments awarded to
employees and Bergen County did not properly maintain relevant or appropriate
supporting documentation of how the lump sum payment amounts were
determined for each employee or the accumulated compensatory hours
employees earned for which the extra duty payments were made. As a result, we
identified unsupported questioned costs totaling $57,000.
17
Substantially dedicated payroll costs meant that personnel must have dedicated over 50 percent
of their time to responding or mitigating COVID-19. Treasury’s Federal Register guidance
indicated: “The full amount of payroll and benefits expenses of substantially dedicated employees
may be covered using payments from the Fund. Treasury has not developed a precise definition of
what "substantially dedicated" means given that there is not a precise way to define this term
across different employment types. The relevant unit of government should maintain
documentation of the "substantially dedicated" conclusion with respect to its employees.”
9
Desk Review of Bergen County, New Jersey
Other Matter for Treasury OIG Consideration – Additional Potential Unsupported
Extra Duty Pay Expenditures
Castro tested $57,000 out of the $243,000 extra duty pay CRF expenditures
reported by Bergen County. The fact that Bergen County did not maintain and
document payroll related expenditures for extra duty pay inherently increases the
risk of potential unsupported costs for the remaining $186,000 of extra duty pay
untested by Castro. We recommend Treasury OIG determine the feasibility of
performing additional follow-up with Bergen County to determine if there were
other instances of unsupported balances within the within the compensatory time
off - extra duty pay portion of the Aggregate Reporting less than $50,000 payment
type.
Conclusion
We determined the expenditures related to the Contracts greater than or equal to
$50,000 and Transfers greater than or equal to $50,000 payment types complied
with the CARES Act and Treasury’s Guidance. We also found that the Direct
Payments greater than or equal to $50,000 payment type complied with the
CARES Act but did not comply with Treasury’s Guidance. Additionally, we found
that the Aggregate Reporting less than $50,000 payment type did not comply with
the CARES Act and Treasury’s Guidance, resulting in unsupported questioned
costs totaling $57,000.
Additionally, Bergen County’s risk of unallowable use of funds is moderate. As a
result of this desk review, we recommend Treasury OIG:
Confirm if the transactions noted as unsupported expenditures within
Aggregate Reporting less than $50,000 can be supported. If support is not
provided, Treasury OIG should recoup the funds or request that Bergen
County management provide support for replacement expenses, not
previously charged, that were eligible during the CRF period of
performance. Further, based on Bergen County’s responsiveness to
Treasury OIG’s requests and its ability to provide sufficient
documentation and/or replace unsupported transactions charged to the
CRF with valid expenditures, we recommend Treasury OIG determine the
feasibility of conducting an audit for the Aggregate Reporting less than
$50,000 payment type.
10
Desk Review of Bergen County, New Jersey
Castro also identified other matters throughout the course of our desk review,
which warrant recommendations to Treasury OIG for additional action. Castro
recommends Treasury OIG:
Determine the feasibility of performing additional follow-up with Bergen
County to determine if there were other instances of unsupported
balances within the compensatory time off - extra duty pay portion of the
Aggregate Reporting less than $50,000 payment type.
*****
All work completed with this letter complies with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Federal Offices of
Inspectors General, which require that the work adheres to the professional
standards of independence, due professional care, and quality assurance to
ensure the accuracy of the information presented. 18 We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
18
https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
11