Audit 29219

2022-003: Written Internal Control Policies and Federal Grant Award Procedures Finding Prior Year Findings: None Department Agency: Department of Interior State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN # 15.252 Type of Finding: Significant Deficiency Questioned Costs: None Criteria: Federal regulations 2 CFR 200.303 states non-Federal entity establish and maintain effective internal control over the Federal awards. Internal controls is generally defined as a process effected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Internal control is not one event or circumstance, but a dynamic and iterative process-actions that permeate an entity's activities and are an integral part of the way auditee management runs the entity. Condition: The Town did not have written internal controls and Federal grant award policies in place. Cause and Effect: The Town is not dependent on Federal revenues, and had significant staff turnover of key positions. Repeat Finding: No Recommendation: We recommend that the Town of Dayton develop and adopt written internal controls and Federal grant award procedures. These policies and procedures need to be reviewed annually based on Federal agencies awarding the Federal funds. Response: Please see the last page of this report for the Town's response to this finding.

2022-004: Written Debarred, Suspended Vendors & Federal Standards of Conflict Finding Prior Year Findings: None Department Agency: Environmental Protection Agency State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN #151.252 Compliance Area: Procurement & Suspension & Debarment (I) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: The Town of Dayton should have written standards of conduct in place to verify any entity (vendor) with which the Town spends Federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees and contractors engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318 and 45 CFR sections 52.203-13 and 52.203-16). Condition: The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors must be documented when engaged in the selection, award and administration of Federal grant contacts. Cause and Effect: The Town of Dayton due to large influx of Federal expenditures. There was not a control in place to ensure that vendors or contractors the Town entered into contracts with were not suspended or debarred before contracts were executed. Without a reliable control in place to ensure compliance, the Town of Dayton could enter into a contract with a suspended or debarred party and have a conflict of interest with the Federal written contracted parties. Repeat Finding: No Recommendation: We recommend that the Town of Dayton put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and should consider The Town of Dayton adopt a policy on procurement for debarment. The town needs to adopt a written policy when spending Federal funds, to ensure no conflict of interest exist. Response: Please see the last page of this report for the Town's response to this finding.

2022-003: Written Internal Control Policies and Federal Grant Award Procedures Finding Prior Year Findings: None Department Agency: Department of Interior State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN # 15.252 Type of Finding: Significant Deficiency Questioned Costs: None Criteria: Federal regulations 2 CFR 200.303 states non-Federal entity establish and maintain effective internal control over the Federal awards. Internal controls is generally defined as a process effected by an entity's oversight body, management, and other personnel that provides reasonable assurance that the objectives of an entity will be achieved. Internal control is not one event or circumstance, but a dynamic and iterative process-actions that permeate an entity's activities and are an integral part of the way auditee management runs the entity. Condition: The Town did not have written internal controls and Federal grant award policies in place. Cause and Effect: The Town is not dependent on Federal revenues, and had significant staff turnover of key positions. Repeat Finding: No Recommendation: We recommend that the Town of Dayton develop and adopt written internal controls and Federal grant award procedures. These policies and procedures need to be reviewed annually based on Federal agencies awarding the Federal funds. Response: Please see the last page of this report for the Town's response to this finding.

2022-004: Written Debarred, Suspended Vendors & Federal Standards of Conflict Finding Prior Year Findings: None Department Agency: Environmental Protection Agency State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN #151.252 Compliance Area: Procurement & Suspension & Debarment (I) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: The Town of Dayton should have written standards of conduct in place to verify any entity (vendor) with which the Town spends Federal expenditures or conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees and contractors engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318 and 45 CFR sections 52.203-13 and 52.203-16). Condition: The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors must be documented when engaged in the selection, award and administration of Federal grant contacts. Cause and Effect: The Town of Dayton due to large influx of Federal expenditures. There was not a control in place to ensure that vendors or contractors the Town entered into contracts with were not suspended or debarred before contracts were executed. Without a reliable control in place to ensure compliance, the Town of Dayton could enter into a contract with a suspended or debarred party and have a conflict of interest with the Federal written contracted parties. Repeat Finding: No Recommendation: We recommend that the Town of Dayton put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and should consider The Town of Dayton adopt a policy on procurement for debarment. The town needs to adopt a written policy when spending Federal funds, to ensure no conflict of interest exist. Response: Please see the last page of this report for the Town's response to this finding.