Audit 292364

FY End
2022-12-31
Total Expended
$2.20M
Findings
2
Programs
3
Organization: City of Ripon (WI)
Year: 2022 Accepted: 2024-02-27

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
370645 2022-003 Material Weakness - I
947087 2022-003 Material Weakness - I

Contacts

Name Title Type
K329RB33YEB1 Amanda Toney Auditee
9207484911 Amber Drewieske, CPA Auditor
No contacts on file

Notes to SEFA

Title: BASIS OF PRESENTATION Accounting Policies: Revenues and expenditures in the schedule are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the City's 2022 financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines for all awards with the exception of ALN 21.027, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The City has not elected to charge a de minimis indirect rate of 10% of modified total direct costs. The accompanying schedule of expenditures of federal awards for the City is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and the State Single Audit Guidelines issued by the Wisconsin Department of Administration. The schedule of expenditures of federal and state awards includes all federal and state awards of the City. Because the schedule presents only a selected portion of the operations of the City, it is not intended to and does not present the financial position, changes in net position, or cash flows of the City.
Title: OVERSIGHT AGENCY Accounting Policies: Revenues and expenditures in the schedule are presented in accordance with the modified accrual basis of accounting and are generally in agreement with revenues and expenditures reported in the City's 2022 financial statements. Such expenditures are recognized following the cost principles contained in the Uniform Guidance and State Single Audit Guidelines for all awards with the exception of ALN 21.027, which follows criteria determined by the Department of Treasury for allowability of costs. Under these principles, certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The City has not elected to charge a de minimis indirect rate of 10% of modified total direct costs. The federal and state oversight agencies for the City are as follows: Federal - U.S. Department of Treasury and the U.S. Department of Housing and Urban Development. State - Wisconsin Department of Transportation

Finding Details

Procurement, Suspension, and Debarment Federal Assistance Listing Number - 21.027 Federal Agency - Department of Treasury Federal Program Title - COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period - 03/31/2021 through 12/31/2024 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, and Other Matter Condition: The City does not have a procurement policy in compliance with UGG requirements, specifically as it relates to retained supporting documentation, which includes not having a policy on suspension & debarment verification. Criteria or Specific Requirement: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the City's written procurement policy on approval thresholds and controls. 2 CFR 200 states that non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Cause: The City has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the City have a policy that covers suspension & debarment. Effect: The City is not in compliance with procurement or suspension & debarment requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold many not be in compliance with the Uniform Guidance. Vendors many be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Recommendation: We recommend the City review and update procurement policies for the entire City to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension & debarment. View of Responsible Officials: There is no disagreement with the finding.
Procurement, Suspension, and Debarment Federal Assistance Listing Number - 21.027 Federal Agency - Department of Treasury Federal Program Title - COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Period - 03/31/2021 through 12/31/2024 Compliance Requirement: Procurement, Suspension, and Debarment Type of Finding: Material Weakness in Internal Control over Compliance, and Other Matter Condition: The City does not have a procurement policy in compliance with UGG requirements, specifically as it relates to retained supporting documentation, which includes not having a policy on suspension & debarment verification. Criteria or Specific Requirement: 2 CFR 200 requires that all procurement transactions for the acquisition of property or services required under a Federal award must be conducted in a manner providing full and open competition consistent with the standards of this section and §200.320. The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Further, the method of procurement, whether informal or formal, must follow the City's written procurement policy on approval thresholds and controls. 2 CFR 200 states that non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Cause: The City has a purchasing policy but not a procurement policy that follows Uniform Guidance (UG) nor does the City have a policy that covers suspension & debarment. Effect: The City is not in compliance with procurement or suspension & debarment requirements. Contracts for construction, non- construction related procurements, and those over the simplified acquisition threshold many not be in compliance with the Uniform Guidance. Vendors many be paid with federal funds that are suspended and debarred entities which would not be in compliance with the Uniform Guidance. Recommendation: We recommend the City review and update procurement policies for the entire City to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension & debarment. View of Responsible Officials: There is no disagreement with the finding.