Audit 1920

FY End
2022-12-31
Total Expended
$6.07M
Findings
6
Programs
28
Organization: Kittitas County (WA)
Year: 2022 Accepted: 2023-10-31

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1009 2022-001 Material Weakness Yes I
1010 2022-001 Material Weakness Yes I
1011 2022-001 Material Weakness Yes I
577451 2022-001 Material Weakness Yes I
577452 2022-001 Material Weakness Yes I
577453 2022-001 Material Weakness Yes I

Programs

ALN Program Spent Major Findings
20.205 Highway Planning and Construction $633,442 Yes 0
10.665 Schools and Roads - Grants to States $316,966 - 0
21.027 Covid 19 - Coronavirus State and Local Fiscal Recovery Funds $189,768 Yes 1
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $140,936 - 0
93.268 Immunization Cooperative Agreements $129,065 - 0
93.070 Environmental Public Health and Emergency Response $107,359 - 0
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $86,708 - 0
20.224 Federal Lands Access Program $79,425 Yes 0
93.323 Covid 19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $68,360 - 0
93.439 State Physical Activity and Nutrition (span $64,241 - 0
10.170 Specialty Crop Block Grant Program - Farm Bill $57,103 - 0
93.069 Public Health Emergency Preparedness $53,046 - 0
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $46,366 - 0
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $45,700 - 0
93.994 Maternal and Child Health Services Block Grant to the States $39,613 - 0
20.106 Airport Improvement Program, Covid-19 Airports Programs, and Infrastructure Investment and Jobs Act Programs $18,812 - 0
16.575 Crime Victim Assistance $16,668 - 0
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation?s Health $16,175 - 0
97.042 Emergency Management Performance Grants $13,919 - 0
16.588 Violence Against Women Formula Grants $11,395 - 0
93.778 Medical Assistance Program $7,379 - 0
16.027 National Clearinghouse on Sexual Assault of American Indian and Alaska Native Women $7,373 - 0
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $6,047 - 0
93.563 Child Support Enforcement $4,756 - 0
97.067 Homeland Security Grant Program $2,994 - 0
97.045 Cooperating Technical Partners $2,959 - 0
97.012 Boating Safety Financial Assistance $2,659 - 0
20.600 State and Community Highway Safety $2,525 - 0

Contacts

Name Title Type
WQ23XPBSAU44 Brian Carlson Auditee
5099627502 Ann Strand Auditor
No contacts on file

Notes to SEFA

Title: Note 2 - Program Cost Accounting Policies: This schedule is prepared on the same basis of accounting as the county’s financial statements. The county uses the modified accrual system of accounting. De Minimis Rate Used: N Rate Explanation: The county has not elected to use the 10-percent de minimis indirect cost rate allowed under the uniform guidance. The amount shown as current year expenditures represent only federal and state grant portion of the program costs. Entire program costs, including the county’s portion, may be more than shown. Such expenditures are recognized following, as applicable, either the cost principles in OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments, or the cost principlescontained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform AdministrativeRequirements, Cost Principles, and Audit Requirements for Federal Awards, wherein certain typesof expenditures are not allowable or are limited as to reimbursement.
Title: Note 3 - Indirect Cost Accounting Policies: This schedule is prepared on the same basis of accounting as the county’s financial statements. The county uses the modified accrual system of accounting. De Minimis Rate Used: N Rate Explanation: The county has not elected to use the 10-percent de minimis indirect cost rate allowed under the uniform guidance. County: The amount expended includes an indirect cost recovery using an approved indirect cost rate of 15.00 percent. Public Health: The amount expended includes an indirect cost recovery using an approved indirect cost rate of 21.00 percent. The county has not elected to use the 10-percent de minimis indirect cost rate allowed under the uniform guidance.
Title: Note 4 - Project has been completed or expired Accounting Policies: This schedule is prepared on the same basis of accounting as the county’s financial statements. The county uses the modified accrual system of accounting. De Minimis Rate Used: N Rate Explanation: The county has not elected to use the 10-percent de minimis indirect cost rate allowed under the uniform guidance. Project has been completed or expired.
Title: Note 5 - In-lieu of Taxes/Unrestricted Funds Accounting Policies: This schedule is prepared on the same basis of accounting as the county’s financial statements. The county uses the modified accrual system of accounting. De Minimis Rate Used: N Rate Explanation: The county has not elected to use the 10-percent de minimis indirect cost rate allowed under the uniform guidance. In lieu of taxes, unrestricted funds used for general operations of County Road Fund

Finding Details

The County’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Assistance Listing Number and Title: 21.027; COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: CLH31015 and CLH31015-CSFRF-CTS LHJ Allocation Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-002 Background The purpose of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected, and make necessary investments in water, sewer or broadband infrastructure. In 2022, the County spent $1,267,984 in program funds for the provision of government services, mitigating the effects of COVID-19 on public health, and supporting the tourism industry. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the County enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors or subrecipients have not been suspended, debarred or otherwise excluded. This requirement also applies to all program subawards, regardless of amount. The County may accomplish this verification by collecting a written certification from the contractor or subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The County must perform this verification before entering into the contract or making the subaward, and it must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the County’s internal controls were inadequate for ensuring staff verified the suspension and debarment status of contractors for purchases exceeding $25,000, paid all or in part with federal funds. Specifically, the County did not retain documentation to demonstrate that staff verified, prior to entering into the covered transactions, that three contractors paid a total of $365,722 in 2022 were not suspended or debarred from participating in federal programs. We consider this internal control deficiency to be a material weakness, which led to material noncompliance. Cause of Condition The County experienced turnover during 2022, and staff could not locate documentation to demonstrate compliance. The County received an audit finding in February 2023 regarding suspension and debarment. At that time, the County verified contractors paid in 2022 were not suspended or debarred; however, the verification occurred after the County had already entered into the contracts. Effect of Condition Without adequate internal controls over suspension and debarment requirements, the County cannot guarantee it is paying federal funds only to eligible contractors. Additionally, the awarding agency could potentially recover any payments the County made to an ineligible party. Since the County subsequently verified the contractors were not suspended and debarred, we are not questioning costs. Recommendation We recommend the County strengthen internal controls to ensure all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. In addition, the County should maintain documentation demonstrating compliance with this federal requirement. County’s Response County acknowledges the need to ensure controls with respect to vendor status, and that prior staff failed to document this internal process for select vendor. County notes that this finding was identified after County’s internal processes were fully revised to address this issue, though the corrective measure was implemented after the identified contracts were executed. Auditor’s Remarks We appreciate the County’s commitment to resolving this finding, and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The County’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Assistance Listing Number and Title: 21.027; COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: CLH31015 and CLH31015-CSFRF-CTS LHJ Allocation Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-002 Background The purpose of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected, and make necessary investments in water, sewer or broadband infrastructure. In 2022, the County spent $1,267,984 in program funds for the provision of government services, mitigating the effects of COVID-19 on public health, and supporting the tourism industry. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the County enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors or subrecipients have not been suspended, debarred or otherwise excluded. This requirement also applies to all program subawards, regardless of amount. The County may accomplish this verification by collecting a written certification from the contractor or subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The County must perform this verification before entering into the contract or making the subaward, and it must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the County’s internal controls were inadequate for ensuring staff verified the suspension and debarment status of contractors for purchases exceeding $25,000, paid all or in part with federal funds. Specifically, the County did not retain documentation to demonstrate that staff verified, prior to entering into the covered transactions, that three contractors paid a total of $365,722 in 2022 were not suspended or debarred from participating in federal programs. We consider this internal control deficiency to be a material weakness, which led to material noncompliance. Cause of Condition The County experienced turnover during 2022, and staff could not locate documentation to demonstrate compliance. The County received an audit finding in February 2023 regarding suspension and debarment. At that time, the County verified contractors paid in 2022 were not suspended or debarred; however, the verification occurred after the County had already entered into the contracts. Effect of Condition Without adequate internal controls over suspension and debarment requirements, the County cannot guarantee it is paying federal funds only to eligible contractors. Additionally, the awarding agency could potentially recover any payments the County made to an ineligible party. Since the County subsequently verified the contractors were not suspended and debarred, we are not questioning costs. Recommendation We recommend the County strengthen internal controls to ensure all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. In addition, the County should maintain documentation demonstrating compliance with this federal requirement. County’s Response County acknowledges the need to ensure controls with respect to vendor status, and that prior staff failed to document this internal process for select vendor. County notes that this finding was identified after County’s internal processes were fully revised to address this issue, though the corrective measure was implemented after the identified contracts were executed. Auditor’s Remarks We appreciate the County’s commitment to resolving this finding, and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The County’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Assistance Listing Number and Title: 21.027; COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: CLH31015 and CLH31015-CSFRF-CTS LHJ Allocation Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-002 Background The purpose of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected, and make necessary investments in water, sewer or broadband infrastructure. In 2022, the County spent $1,267,984 in program funds for the provision of government services, mitigating the effects of COVID-19 on public health, and supporting the tourism industry. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the County enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors or subrecipients have not been suspended, debarred or otherwise excluded. This requirement also applies to all program subawards, regardless of amount. The County may accomplish this verification by collecting a written certification from the contractor or subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The County must perform this verification before entering into the contract or making the subaward, and it must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the County’s internal controls were inadequate for ensuring staff verified the suspension and debarment status of contractors for purchases exceeding $25,000, paid all or in part with federal funds. Specifically, the County did not retain documentation to demonstrate that staff verified, prior to entering into the covered transactions, that three contractors paid a total of $365,722 in 2022 were not suspended or debarred from participating in federal programs. We consider this internal control deficiency to be a material weakness, which led to material noncompliance. Cause of Condition The County experienced turnover during 2022, and staff could not locate documentation to demonstrate compliance. The County received an audit finding in February 2023 regarding suspension and debarment. At that time, the County verified contractors paid in 2022 were not suspended or debarred; however, the verification occurred after the County had already entered into the contracts. Effect of Condition Without adequate internal controls over suspension and debarment requirements, the County cannot guarantee it is paying federal funds only to eligible contractors. Additionally, the awarding agency could potentially recover any payments the County made to an ineligible party. Since the County subsequently verified the contractors were not suspended and debarred, we are not questioning costs. Recommendation We recommend the County strengthen internal controls to ensure all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. In addition, the County should maintain documentation demonstrating compliance with this federal requirement. County’s Response County acknowledges the need to ensure controls with respect to vendor status, and that prior staff failed to document this internal process for select vendor. County notes that this finding was identified after County’s internal processes were fully revised to address this issue, though the corrective measure was implemented after the identified contracts were executed. Auditor’s Remarks We appreciate the County’s commitment to resolving this finding, and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The County’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Assistance Listing Number and Title: 21.027; COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: CLH31015 and CLH31015-CSFRF-CTS LHJ Allocation Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-002 Background The purpose of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected, and make necessary investments in water, sewer or broadband infrastructure. In 2022, the County spent $1,267,984 in program funds for the provision of government services, mitigating the effects of COVID-19 on public health, and supporting the tourism industry. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the County enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors or subrecipients have not been suspended, debarred or otherwise excluded. This requirement also applies to all program subawards, regardless of amount. The County may accomplish this verification by collecting a written certification from the contractor or subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The County must perform this verification before entering into the contract or making the subaward, and it must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the County’s internal controls were inadequate for ensuring staff verified the suspension and debarment status of contractors for purchases exceeding $25,000, paid all or in part with federal funds. Specifically, the County did not retain documentation to demonstrate that staff verified, prior to entering into the covered transactions, that three contractors paid a total of $365,722 in 2022 were not suspended or debarred from participating in federal programs. We consider this internal control deficiency to be a material weakness, which led to material noncompliance. Cause of Condition The County experienced turnover during 2022, and staff could not locate documentation to demonstrate compliance. The County received an audit finding in February 2023 regarding suspension and debarment. At that time, the County verified contractors paid in 2022 were not suspended or debarred; however, the verification occurred after the County had already entered into the contracts. Effect of Condition Without adequate internal controls over suspension and debarment requirements, the County cannot guarantee it is paying federal funds only to eligible contractors. Additionally, the awarding agency could potentially recover any payments the County made to an ineligible party. Since the County subsequently verified the contractors were not suspended and debarred, we are not questioning costs. Recommendation We recommend the County strengthen internal controls to ensure all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. In addition, the County should maintain documentation demonstrating compliance with this federal requirement. County’s Response County acknowledges the need to ensure controls with respect to vendor status, and that prior staff failed to document this internal process for select vendor. County notes that this finding was identified after County’s internal processes were fully revised to address this issue, though the corrective measure was implemented after the identified contracts were executed. Auditor’s Remarks We appreciate the County’s commitment to resolving this finding, and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The County’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Assistance Listing Number and Title: 21.027; COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: CLH31015 and CLH31015-CSFRF-CTS LHJ Allocation Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-002 Background The purpose of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected, and make necessary investments in water, sewer or broadband infrastructure. In 2022, the County spent $1,267,984 in program funds for the provision of government services, mitigating the effects of COVID-19 on public health, and supporting the tourism industry. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the County enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors or subrecipients have not been suspended, debarred or otherwise excluded. This requirement also applies to all program subawards, regardless of amount. The County may accomplish this verification by collecting a written certification from the contractor or subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The County must perform this verification before entering into the contract or making the subaward, and it must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the County’s internal controls were inadequate for ensuring staff verified the suspension and debarment status of contractors for purchases exceeding $25,000, paid all or in part with federal funds. Specifically, the County did not retain documentation to demonstrate that staff verified, prior to entering into the covered transactions, that three contractors paid a total of $365,722 in 2022 were not suspended or debarred from participating in federal programs. We consider this internal control deficiency to be a material weakness, which led to material noncompliance. Cause of Condition The County experienced turnover during 2022, and staff could not locate documentation to demonstrate compliance. The County received an audit finding in February 2023 regarding suspension and debarment. At that time, the County verified contractors paid in 2022 were not suspended or debarred; however, the verification occurred after the County had already entered into the contracts. Effect of Condition Without adequate internal controls over suspension and debarment requirements, the County cannot guarantee it is paying federal funds only to eligible contractors. Additionally, the awarding agency could potentially recover any payments the County made to an ineligible party. Since the County subsequently verified the contractors were not suspended and debarred, we are not questioning costs. Recommendation We recommend the County strengthen internal controls to ensure all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. In addition, the County should maintain documentation demonstrating compliance with this federal requirement. County’s Response County acknowledges the need to ensure controls with respect to vendor status, and that prior staff failed to document this internal process for select vendor. County notes that this finding was identified after County’s internal processes were fully revised to address this issue, though the corrective measure was implemented after the identified contracts were executed. Auditor’s Remarks We appreciate the County’s commitment to resolving this finding, and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.
The County’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Assistance Listing Number and Title: 21.027; COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Federal Grantor Name: U.S. Department of the Treasury Federal Award/Contract Number: N/A Pass-through Entity Name: Washington State Department of Commerce Pass-through Award/Contract Number: CLH31015 and CLH31015-CSFRF-CTS LHJ Allocation Known Questioned Cost Amount: $0 Prior Year Audit Finding: Yes, Finding 2021-002 Background The purpose of the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) is to respond to the COVID-19 pandemic’s negative effects on public health and the economy, provide premium pay to essential workers during the pandemic, provide government services to the extent COVID-19 caused a reduction in revenues collected, and make necessary investments in water, sewer or broadband infrastructure. In 2022, the County spent $1,267,984 in program funds for the provision of government services, mitigating the effects of COVID-19 on public health, and supporting the tourism industry. Federal regulations require recipients to establish and follow internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. Federal requirements prohibit recipients from contracting with or purchasing from parties suspended or debarred from doing business with the federal government. Whenever the County enters into contracts or purchases goods or services that it expects to equal or exceed $25,000, paid all or in part with federal funds, it must verify the contractors or subrecipients have not been suspended, debarred or otherwise excluded. This requirement also applies to all program subawards, regardless of amount. The County may accomplish this verification by collecting a written certification from the contractor or subrecipient, adding a clause or condition into the contract that states the contractor or subrecipient is not suspended or debarred, or checking for exclusion records in the U.S. General Services Administration’s System for Award Management at SAM.gov. The County must perform this verification before entering into the contract or making the subaward, and it must maintain documentation demonstrating compliance with this federal requirement. Description of Condition Our audit found the County’s internal controls were inadequate for ensuring staff verified the suspension and debarment status of contractors for purchases exceeding $25,000, paid all or in part with federal funds. Specifically, the County did not retain documentation to demonstrate that staff verified, prior to entering into the covered transactions, that three contractors paid a total of $365,722 in 2022 were not suspended or debarred from participating in federal programs. We consider this internal control deficiency to be a material weakness, which led to material noncompliance. Cause of Condition The County experienced turnover during 2022, and staff could not locate documentation to demonstrate compliance. The County received an audit finding in February 2023 regarding suspension and debarment. At that time, the County verified contractors paid in 2022 were not suspended or debarred; however, the verification occurred after the County had already entered into the contracts. Effect of Condition Without adequate internal controls over suspension and debarment requirements, the County cannot guarantee it is paying federal funds only to eligible contractors. Additionally, the awarding agency could potentially recover any payments the County made to an ineligible party. Since the County subsequently verified the contractors were not suspended and debarred, we are not questioning costs. Recommendation We recommend the County strengthen internal controls to ensure all contractors it expects to pay $25,000 or more, all or in part with federal funds, are not suspended or debarred from participating in federal programs. In addition, the County should maintain documentation demonstrating compliance with this federal requirement. County’s Response County acknowledges the need to ensure controls with respect to vendor status, and that prior staff failed to document this internal process for select vendor. County notes that this finding was identified after County’s internal processes were fully revised to address this issue, though the corrective measure was implemented after the identified contracts were executed. Auditor’s Remarks We appreciate the County’s commitment to resolving this finding, and thank the County for its cooperation and assistance during the audit. We will review the corrective action taken during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 2 CFR Part 180, OMB Guidelines to Agencies on Governmentwide Debarment and Suspension (Nonprocurement), establishes nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689.