WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
INELIGIBLE COSTS / CRITERIA / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINSTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATES "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / CONDITION / ON MAY 11, 2022 THE CITY WAS AWARDED AN ARPA GRANT THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY. COSTS OF DEMOLITION WERE SUBMITTED AND REIMBURSED BY THE MISSISSIPPI COUNTY, MISSOURI ARPA GRANT IN AUGUST AND SEPTEMBER 2022. ON DECEMBER 12, 2022, THE CITY WAS AWARDED AN ARPA GRANT THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION (DESE) FOR THE SAME PROJECT. THE GRANT REQUIRED A 50% MATCH. THE BUDGET SUBMITTED TO DESE INDICATED THAT THE GRANT FROM MISSISSIPPI COUNTY, MISSOURI WOULD BE USED AS A MATCH. ON DECEMBER 14, 2022, THE CITY SUBMITTED INVOICES TO DESE FOR REIMBURSEMENT IN THE AMOUNT OF $94,921.26. THE INVOICES SUBMITTED HAD PREVIOUSLY BEEN REIMBURSED BY THE MISSISSIPPI COUNTY ARPA GRANT. THUS, THE CLAIM FOR REIMBURSEMENT WAS DUPLICATED, AND THE CITY WAS REIMBURSED TWICE FOR THE SAME COSTS. / CAUSE / THE CITY RECEIVED A MISCOMMUNICATION REGARDING THE ELIGIBILITY OF COSTS. ALSO, THE CITY WAS NO FULLY AWARE OF THE COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. / EFFECT / THE CITY HAS DUPLICATED THE REQUEST FOR REIMBURSEMENT OF COSTS SUBMITTED TO THE DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND THE MISSISSIPPI COUNTY, MISSOURI IN THE AMOUNT OF $94,921.26. / QUESTIONED COSTS / THE AMOUNT OF $94,921.26 IS BEING QUESTIONED, SINCE THE COST HAS PREVIOUSLY BEEN REPORTED AS A COST OF ANOTHER PROGRAM. / PERSPECTIVE / THE FINDING IS AN ISOLATED INSTANCE, IN THAT THE QUESTIONED COSTS PERTAINED TO A SINGLE INVOICE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / I WOULD RECOMMEND CONTACTING THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND MISSISSIPPI COUNTY, MISSOURI, AND ADVISE THEM OF THE QUESTIONED COSTS. I WOULD RECOMMEND FILING AMENDED REPORTS AS NEEDED. ALSO, I WOULD RECOMMEND REQUESTING THAT OTHER ELIGIBLE COSTS BE SUBSTITUTED FOR THE REIMBURSEMENT. I WOULD ALSO RECOMMEND THAT THE CITY ADMINISTRATIVE STAFF FULLY REVIEW THE ADMINISTRATIVE AND COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. FURTHER, THE CITY SHOULD CONSULT WITH AN OUTSIDE PROFESSIONAL AS NEEDED. / MANAGEMENT RESPONSE / MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTACT THE GRANTOR AGENCIES TO RESOLVE THE MATTER AS QUICKLY AS POSSIBLE. FURTHER, THE ADMINISTRATIVE STAFF WILL RECEIVE TRAINING IN REGARDS TO THE ADMINISTRATIVE AND COST STANDARDS OF THE UNIFORM GUIDANCE. ALSO, OUTSIDE PROFESSIONALS WILL BE CONSULTED AS NEEDED.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
INELIGIBLE COSTS / CRITERIA / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINSTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATES "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / CONDITION / ON MAY 11, 2022 THE CITY WAS AWARDED AN ARPA GRANT THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY. COSTS OF DEMOLITION WERE SUBMITTED AND REIMBURSED BY THE MISSISSIPPI COUNTY, MISSOURI ARPA GRANT IN AUGUST AND SEPTEMBER 2022. ON DECEMBER 12, 2022, THE CITY WAS AWARDED AN ARPA GRANT THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION (DESE) FOR THE SAME PROJECT. THE GRANT REQUIRED A 50% MATCH. THE BUDGET SUBMITTED TO DESE INDICATED THAT THE GRANT FROM MISSISSIPPI COUNTY, MISSOURI WOULD BE USED AS A MATCH. ON DECEMBER 14, 2022, THE CITY SUBMITTED INVOICES TO DESE FOR REIMBURSEMENT IN THE AMOUNT OF $94,921.26. THE INVOICES SUBMITTED HAD PREVIOUSLY BEEN REIMBURSED BY THE MISSISSIPPI COUNTY ARPA GRANT. THUS, THE CLAIM FOR REIMBURSEMENT WAS DUPLICATED, AND THE CITY WAS REIMBURSED TWICE FOR THE SAME COSTS. / CAUSE / THE CITY RECEIVED A MISCOMMUNICATION REGARDING THE ELIGIBILITY OF COSTS. ALSO, THE CITY WAS NO FULLY AWARE OF THE COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. / EFFECT / THE CITY HAS DUPLICATED THE REQUEST FOR REIMBURSEMENT OF COSTS SUBMITTED TO THE DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND THE MISSISSIPPI COUNTY, MISSOURI IN THE AMOUNT OF $94,921.26. / QUESTIONED COSTS / THE AMOUNT OF $94,921.26 IS BEING QUESTIONED, SINCE THE COST HAS PREVIOUSLY BEEN REPORTED AS A COST OF ANOTHER PROGRAM. / PERSPECTIVE / THE FINDING IS AN ISOLATED INSTANCE, IN THAT THE QUESTIONED COSTS PERTAINED TO A SINGLE INVOICE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / I WOULD RECOMMEND CONTACTING THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND MISSISSIPPI COUNTY, MISSOURI, AND ADVISE THEM OF THE QUESTIONED COSTS. I WOULD RECOMMEND FILING AMENDED REPORTS AS NEEDED. ALSO, I WOULD RECOMMEND REQUESTING THAT OTHER ELIGIBLE COSTS BE SUBSTITUTED FOR THE REIMBURSEMENT. I WOULD ALSO RECOMMEND THAT THE CITY ADMINISTRATIVE STAFF FULLY REVIEW THE ADMINISTRATIVE AND COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. FURTHER, THE CITY SHOULD CONSULT WITH AN OUTSIDE PROFESSIONAL AS NEEDED. / MANAGEMENT RESPONSE / MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTACT THE GRANTOR AGENCIES TO RESOLVE THE MATTER AS QUICKLY AS POSSIBLE. FURTHER, THE ADMINISTRATIVE STAFF WILL RECEIVE TRAINING IN REGARDS TO THE ADMINISTRATIVE AND COST STANDARDS OF THE UNIFORM GUIDANCE. ALSO, OUTSIDE PROFESSIONALS WILL BE CONSULTED AS NEEDED.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
INELIGIBLE COSTS / CRITERIA / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINSTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATES "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / CONDITION / ON MAY 11, 2022 THE CITY WAS AWARDED AN ARPA GRANT THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY. COSTS OF DEMOLITION WERE SUBMITTED AND REIMBURSED BY THE MISSISSIPPI COUNTY, MISSOURI ARPA GRANT IN AUGUST AND SEPTEMBER 2022. ON DECEMBER 12, 2022, THE CITY WAS AWARDED AN ARPA GRANT THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION (DESE) FOR THE SAME PROJECT. THE GRANT REQUIRED A 50% MATCH. THE BUDGET SUBMITTED TO DESE INDICATED THAT THE GRANT FROM MISSISSIPPI COUNTY, MISSOURI WOULD BE USED AS A MATCH. ON DECEMBER 14, 2022, THE CITY SUBMITTED INVOICES TO DESE FOR REIMBURSEMENT IN THE AMOUNT OF $94,921.26. THE INVOICES SUBMITTED HAD PREVIOUSLY BEEN REIMBURSED BY THE MISSISSIPPI COUNTY ARPA GRANT. THUS, THE CLAIM FOR REIMBURSEMENT WAS DUPLICATED, AND THE CITY WAS REIMBURSED TWICE FOR THE SAME COSTS. / CAUSE / THE CITY RECEIVED A MISCOMMUNICATION REGARDING THE ELIGIBILITY OF COSTS. ALSO, THE CITY WAS NO FULLY AWARE OF THE COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. / EFFECT / THE CITY HAS DUPLICATED THE REQUEST FOR REIMBURSEMENT OF COSTS SUBMITTED TO THE DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND THE MISSISSIPPI COUNTY, MISSOURI IN THE AMOUNT OF $94,921.26. / QUESTIONED COSTS / THE AMOUNT OF $94,921.26 IS BEING QUESTIONED, SINCE THE COST HAS PREVIOUSLY BEEN REPORTED AS A COST OF ANOTHER PROGRAM. / PERSPECTIVE / THE FINDING IS AN ISOLATED INSTANCE, IN THAT THE QUESTIONED COSTS PERTAINED TO A SINGLE INVOICE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / I WOULD RECOMMEND CONTACTING THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND MISSISSIPPI COUNTY, MISSOURI, AND ADVISE THEM OF THE QUESTIONED COSTS. I WOULD RECOMMEND FILING AMENDED REPORTS AS NEEDED. ALSO, I WOULD RECOMMEND REQUESTING THAT OTHER ELIGIBLE COSTS BE SUBSTITUTED FOR THE REIMBURSEMENT. I WOULD ALSO RECOMMEND THAT THE CITY ADMINISTRATIVE STAFF FULLY REVIEW THE ADMINISTRATIVE AND COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. FURTHER, THE CITY SHOULD CONSULT WITH AN OUTSIDE PROFESSIONAL AS NEEDED. / MANAGEMENT RESPONSE / MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTACT THE GRANTOR AGENCIES TO RESOLVE THE MATTER AS QUICKLY AS POSSIBLE. FURTHER, THE ADMINISTRATIVE STAFF WILL RECEIVE TRAINING IN REGARDS TO THE ADMINISTRATIVE AND COST STANDARDS OF THE UNIFORM GUIDANCE. ALSO, OUTSIDE PROFESSIONALS WILL BE CONSULTED AS NEEDED.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
WRITTEN POLICIES AND PROCEDURES / CRITERIA/ UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART D - POST FEDERAL AWARD REQUIREMENTS SECTION 200.300 THROUGH 200.346 REQUIRES THAT THE GRANTEE ESTABLISH WRITTEN POLICIES AND PROCEDURES FOR ADMINISTRATION OF THE APPLICABLE FEDERAL COMPLIANCE REQUIREMENTS. / CONDITION / THE CITY HAS APPROVED WRITTEN POLICIES AND PROCEDURES FOR PROCUREMENT AND CONFLICTS OF INTEREST. HOWEVER, THE APPROVED PROCEDURES DO NOT CONTAIN ALL THE REQUIRED ELEMENTS OF THE UNIFORM GUIDANCE. / CAUSE / THE CITY WAS NOT AWARE THAT UNIFORM GUIDANCE REQUIRED WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT / EFFECT / THE RISK OF NONCOMPLIANCE WITH AN APPLICABLE COMPLIANCE REQUIREMENT IS INCREASED WITHOUT WRITTEN POLICIES AND PROCEDURES. / QUESTIONED COSTS / THERE ARE NOT ANY QUESTIONED COSTS AS A RESULT OF THIS FINDING. / PERSPECTIVE / THE CONDITION WOULD BE CONSIDERED SYSTEMATIC, IN THAT THE CITY'S WRITTEN PROCEDURES DO NOT ADDRESS THE REQUIREMENTS OF UNIFORM GUIDANCE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / THE CITY SHOULD REVIEW THE REQUIREMENTS OF EACH FEDERAL PROGRAM AND DEVELOP WRITTEN POLICIES AND PROCEDURES FOR EACH APPLICABLE COMPLIANCE REQUIREMENT. THE CITY SHOULD ADOPT A WRITTEN GRANT MANAGEMENT POLICY THAT INCORPORATES UNIFORM GUIDANCE AND IS APPLICABLE TO FEDERAL AWARDS. / MANAGEMENT RESPONSE / THE CITY AGREES WITH THE FINDING. IN SUBSEQUENT YEARS, THE CITY WILL REVIEW THE FEDERAL PROGRAMS AND DEVELOP WRITTEN POLICIES AND PROCEDURES THAT ADDRESS THE ADMINISTRATION OF EACH APPLICABLE FEDERAL COMPLIANCE REQUIREMENT IN CONFORMITY WITH UNIFORM GUIDANCE.
INELIGIBLE COSTS / CRITERIA / UNIFORM GUIDANCE 2 CFR PART 200 UNIFORM ADMINSTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, SUBPART E: COST PRINCIPLES SECTION 200.403(F) STATES "EXCEPT WHERE OTHERWISE AUTHORIZED BY STATUTE, COSTS MUST MEET THE FOLLOWING CRITERIA IN ORDER TO BE ALLOWABLE UNDER FEDERAL AWARDS: (F) NOT BE INCLUDED AS A COST OR USED TO MEET COST SHARING OR MATCHING REQUIREMENTS OF ANY OTHER FEDERALLY-FINANCED PROGRAM IN EITHER THE CURRENT OR PRIOR PERIOD. / CONDITION / ON MAY 11, 2022 THE CITY WAS AWARDED AN ARPA GRANT THROUGH MISSISSIPPI COUNTY, MISSOURI FOR THE DEMOLITION OF A HAZARDOUS SCHOOL STRUCTURE IN ORDER TO FACILITATE THE CONSTRUCTION OF A PUBLIC HEALTH FACILITY. COSTS OF DEMOLITION WERE SUBMITTED AND REIMBURSED BY THE MISSISSIPPI COUNTY, MISSOURI ARPA GRANT IN AUGUST AND SEPTEMBER 2022. ON DECEMBER 12, 2022, THE CITY WAS AWARDED AN ARPA GRANT THROUGH THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION (DESE) FOR THE SAME PROJECT. THE GRANT REQUIRED A 50% MATCH. THE BUDGET SUBMITTED TO DESE INDICATED THAT THE GRANT FROM MISSISSIPPI COUNTY, MISSOURI WOULD BE USED AS A MATCH. ON DECEMBER 14, 2022, THE CITY SUBMITTED INVOICES TO DESE FOR REIMBURSEMENT IN THE AMOUNT OF $94,921.26. THE INVOICES SUBMITTED HAD PREVIOUSLY BEEN REIMBURSED BY THE MISSISSIPPI COUNTY ARPA GRANT. THUS, THE CLAIM FOR REIMBURSEMENT WAS DUPLICATED, AND THE CITY WAS REIMBURSED TWICE FOR THE SAME COSTS. / CAUSE / THE CITY RECEIVED A MISCOMMUNICATION REGARDING THE ELIGIBILITY OF COSTS. ALSO, THE CITY WAS NO FULLY AWARE OF THE COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. / EFFECT / THE CITY HAS DUPLICATED THE REQUEST FOR REIMBURSEMENT OF COSTS SUBMITTED TO THE DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND THE MISSISSIPPI COUNTY, MISSOURI IN THE AMOUNT OF $94,921.26. / QUESTIONED COSTS / THE AMOUNT OF $94,921.26 IS BEING QUESTIONED, SINCE THE COST HAS PREVIOUSLY BEEN REPORTED AS A COST OF ANOTHER PROGRAM. / PERSPECTIVE / THE FINDING IS AN ISOLATED INSTANCE, IN THAT THE QUESTIONED COSTS PERTAINED TO A SINGLE INVOICE. / PRIOR FINDING / THE CITY DID NOT HAVE A SINGLE AUDIT IN THE PRIOR YEAR, AND THEREFORE PRIOR AUDIT FINDINGS DO NOT APPLY TO THIS MATTER. / RECOMMENDATIONS / I WOULD RECOMMEND CONTACTING THE MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION AND MISSISSIPPI COUNTY, MISSOURI, AND ADVISE THEM OF THE QUESTIONED COSTS. I WOULD RECOMMEND FILING AMENDED REPORTS AS NEEDED. ALSO, I WOULD RECOMMEND REQUESTING THAT OTHER ELIGIBLE COSTS BE SUBSTITUTED FOR THE REIMBURSEMENT. I WOULD ALSO RECOMMEND THAT THE CITY ADMINISTRATIVE STAFF FULLY REVIEW THE ADMINISTRATIVE AND COST STANDARDS CONTAINED IN UNIFORM GUIDANCE. FURTHER, THE CITY SHOULD CONSULT WITH AN OUTSIDE PROFESSIONAL AS NEEDED. / MANAGEMENT RESPONSE / MANAGEMENT AGREES WITH THE FINDING. MANAGEMENT WILL CONTACT THE GRANTOR AGENCIES TO RESOLVE THE MATTER AS QUICKLY AS POSSIBLE. FURTHER, THE ADMINISTRATIVE STAFF WILL RECEIVE TRAINING IN REGARDS TO THE ADMINISTRATIVE AND COST STANDARDS OF THE UNIFORM GUIDANCE. ALSO, OUTSIDE PROFESSIONALS WILL BE CONSULTED AS NEEDED.