Audit 26116

Finding 2022-001: Significant deficiency in internal control over procurement. Federal Agency Program: U.S. Department of Treasury, Passed through State of Oregon ? Department of Administrative Services Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Period: January 1, 2022 ? December 31, 2022 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.318 requires that non-Federal entities must have and use documented procurement procedures, which must conform to the procurement standards in 2 CFR Part 200.318 through 200.327. Procurement procedures must reflect applicable State and local laws and regulations and compliance with the award terms and conditions. The Federal Award agreement stipulated the Organization to require its contractors and sub-contractors to pay the applicable prevailing wage rate. Condition: During the audit, we noted that the Organization was not able to provide documentation to demonstrate that a contractor was required to comply with the prevailing wage requirement in one contract awarded under the Federal Award. Context: There was one contract awarded under the Federal Award, which was selected for testing. Cause: The Organization received increased support during the year ended December 31, 2022, increasing the complexities of compliance with Federal awards. Policies and procedures over procurement were not adequately documented. Effect: Without adequate written policies and procedures over procurement, there is an increased risk of non-compliance with the procurement requirements of 2 CFR 200 and with the terms and conditions of Federal Awards. Questioned costs: None. Repeat Finding: No. Recommendation: The Organization should update its written policies and procedures over procurement consistent with the framework set forth by 2 CFR 200 to ensure compliance with procurement requirements and terms and conditions of Federal Awards. Views of Responsible Officials: Management notes the details of this finding. Management will implement procedures to mitigate the outlined issues in our Corrective Action Plan.

Finding 2022-002: Significant deficiency in internal control over reporting. Federal Agency Program: U.S. Department of Treasury, Passed through State of Oregon ? Department of Administrative Services Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Period: January 1, 2022 ? December 31, 2022 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.329 requires that non-Federal entities submit performance reports at the interval required by the Federal awarding agency or pass-through entity. The grant agreement required quarterly and annual reports to be submitted. Condition: The quarterly reports and the annual reporting submitted for 2022 by the Organization did not agree to the quarterly information as per the Organization?s accounting records provided. Total award expenditures for the year agreed to the total annual amount reported. Context: Additional procedures were required to reconcile the Federal Award expenditures to the annual reporting submitted. Cause: The Organization received increased support during the year ended December 31, 2022, increasing the complexities of tracking and reporting of Federal expenditures. Policies and procedures over the review and approval of Federal award reporting were not adequately documented. Effect: Without adequate written policies and procedures over the review and approval of reporting of Federal award expenditures, total expenditures by Federal program may not be properly reported. Questioned costs: None. Repeat Finding: No. Recommendation: The Organization should update its written policies and procedures over the review and approval of Federal Award reporting to ensure complete and accurate reporting of award expenditures. Views of Responsible Officials: Management notes the details of this finding. Management will implement procedures to mitigate the outlined issues in our Corrective Action Plan.

Finding 2022-001: Significant deficiency in internal control over procurement. Federal Agency Program: U.S. Department of Treasury, Passed through State of Oregon ? Department of Administrative Services Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Period: January 1, 2022 ? December 31, 2022 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200.318 requires that non-Federal entities must have and use documented procurement procedures, which must conform to the procurement standards in 2 CFR Part 200.318 through 200.327. Procurement procedures must reflect applicable State and local laws and regulations and compliance with the award terms and conditions. The Federal Award agreement stipulated the Organization to require its contractors and sub-contractors to pay the applicable prevailing wage rate. Condition: During the audit, we noted that the Organization was not able to provide documentation to demonstrate that a contractor was required to comply with the prevailing wage requirement in one contract awarded under the Federal Award. Context: There was one contract awarded under the Federal Award, which was selected for testing. Cause: The Organization received increased support during the year ended December 31, 2022, increasing the complexities of compliance with Federal awards. Policies and procedures over procurement were not adequately documented. Effect: Without adequate written policies and procedures over procurement, there is an increased risk of non-compliance with the procurement requirements of 2 CFR 200 and with the terms and conditions of Federal Awards. Questioned costs: None. Repeat Finding: No. Recommendation: The Organization should update its written policies and procedures over procurement consistent with the framework set forth by 2 CFR 200 to ensure compliance with procurement requirements and terms and conditions of Federal Awards. Views of Responsible Officials: Management notes the details of this finding. Management will implement procedures to mitigate the outlined issues in our Corrective Action Plan.

Finding 2022-002: Significant deficiency in internal control over reporting. Federal Agency Program: U.S. Department of Treasury, Passed through State of Oregon ? Department of Administrative Services Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Award Period: January 1, 2022 ? December 31, 2022 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.329 requires that non-Federal entities submit performance reports at the interval required by the Federal awarding agency or pass-through entity. The grant agreement required quarterly and annual reports to be submitted. Condition: The quarterly reports and the annual reporting submitted for 2022 by the Organization did not agree to the quarterly information as per the Organization?s accounting records provided. Total award expenditures for the year agreed to the total annual amount reported. Context: Additional procedures were required to reconcile the Federal Award expenditures to the annual reporting submitted. Cause: The Organization received increased support during the year ended December 31, 2022, increasing the complexities of tracking and reporting of Federal expenditures. Policies and procedures over the review and approval of Federal award reporting were not adequately documented. Effect: Without adequate written policies and procedures over the review and approval of reporting of Federal award expenditures, total expenditures by Federal program may not be properly reported. Questioned costs: None. Repeat Finding: No. Recommendation: The Organization should update its written policies and procedures over the review and approval of Federal Award reporting to ensure complete and accurate reporting of award expenditures. Views of Responsible Officials: Management notes the details of this finding. Management will implement procedures to mitigate the outlined issues in our Corrective Action Plan.