Audit 294695

FY End
2023-06-30
Total Expended
$12.61M
Findings
4
Programs
10
Year: 2023 Accepted: 2024-03-12

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
375629 2023-001 Significant Deficiency - I
375630 2023-001 Significant Deficiency - I
952071 2023-001 Significant Deficiency - I
952072 2023-001 Significant Deficiency - I

Contacts

Name Title Type
NE3JSLQVNMZ3 Julie Mussog Auditee
2029623362 Sean Walker Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1: SINGLE AUDIT REPORTING ENTITY Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through identifying numbers are presented where available and applicable. De Minimis Rate Used: N Rate Explanation: The auditee did not to use the de minimis cost rate. The Metropolitan Washington Council of Governments (MWCOG) is an independent, nonprofit association with a membership of elected officials from 24 local governments, the Maryland and Virginia state legislatures, and U.S. Congress. It serves as a hub for regional partnership, sharing information and developing solutions to the region’s major challenges.
Title: NOTE 2: BASIS OF ACCOUNTING Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through identifying numbers are presented where available and applicable. De Minimis Rate Used: N Rate Explanation: The auditee did not to use the de minimis cost rate. The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Metropolitan Washington Council of Governments (MWCOG) under programs of the federal government for the year ended June 30, 2023. The information in this Schedule 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). Because the Schedule presents only a selected portion of the operations of MWCOG, it is not intended to and does not present the financial position or changes in financial position of MWCOG. Federal Financial Assistance – The Single Audit Act Amendments of 1996 (Public Law 104-156) and Uniform Guidance define federal financial assistance as grants, loans, loan guarantees, property (including donated surplus property), cooperative agreements, interest subsidies, insurance, food commodities, direct appropriations, or other assistance. Direct Payments – Assistance received directly from the federal government is classified as direct payments on the Schedule. Pass-through Payments – Assistance received in a pass-through relationship from entities other than the federal government is classified as pass-through payments on the Schedule. Major Programs – The Single Audit Act Amendments of 1996 and Uniform Guidance establish the criteria to be used in defining major programs. Major programs for MWCOG were determined using a risk-based approach in accordance with Uniform Guidance.
Title: NOTE 3: SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through identifying numbers are presented where available and applicable. De Minimis Rate Used: N Rate Explanation: The auditee did not to use the de minimis cost rate. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through identifying numbers are presented where available and applicable.
Title: NOTE 4: INDIRECT COST RATE Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through identifying numbers are presented where available and applicable. De Minimis Rate Used: N Rate Explanation: The auditee did not to use the de minimis cost rate. MWCOG’s indirect cost rates as allowed under the Uniform Guidance are disclosed in Note 1, Fringe Benefit and Indirect Cost Allocations in the notes to financial statements.
Title: NOTE 5: CONTRACTS WITH STATE AND LOCAL GOVERNMENTS CONTAINING FEDERAL FUNDS Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through identifying numbers are presented where available and applicable. De Minimis Rate Used: N Rate Explanation: The auditee did not to use the de minimis cost rate. Under § 200.331, Subrecipient and Contractor Determinations of 2 CFR Part 200, Uniform Guidance explains that MWCOG may concurrently receive federal awards as a recipient, a subrecipient, and a contractor on the substance of its agreements with federal awarding agencies and pass-through entities. Therefore, a case-by-case determination of whether each agreement casts MWCOG’s role as a subrecipient or a contractor is required to ensure the completeness of the Schedule. MWCOG enters into several agreements where the relationship has been determined, based on § 200.331(b), to be a contractor to provide services to federal programs where state and local governments are responsible for compliance with the federal program requirements. Those programs are excluded from the Schedule. These agreements do not have the characteristics of subrecipients, based on § 200.331(a) and appropriate notification under § 200.211, Information Contained in a Federal Award was not made.

Finding Details

Reference Number: 2023-001 Prior Year Finding: No Federal Agency: Pass-Through Agency: U.S. Department of Homeland Security Government of the District of Columbia Homeland Security and Emergency Management Agency Federal Program: Securing the Cities Program Assistance Listing Number: 97.106 Award Number and Year: 17STC117-02, 20STC117-01 (9/1/2021-8/31/2023) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: MWCOG did not determine the suspension and debarment status of vendors with expenditures exceeding $25,000 as required by federal regulations. Context: The suspension and debarment status for 2 of 2 vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: MWCOG’s internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status is documented. Effect: Failure to verify and document the suspension and debarment status of vendors may result in MWCOG issuing payments to vendors that are suspended or debarred and not authorized to provide services under the program. Recommendation: MWCOG should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors. Views of responsible officials: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors.
Reference Number: 2023-001 Prior Year Finding: No Federal Agency: Pass-Through Agency: U.S. Department of Homeland Security Government of the District of Columbia Homeland Security and Emergency Management Agency Federal Program: Securing the Cities Program Assistance Listing Number: 97.106 Award Number and Year: 17STC117-02, 20STC117-01 (9/1/2021-8/31/2023) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: MWCOG did not determine the suspension and debarment status of vendors with expenditures exceeding $25,000 as required by federal regulations. Context: The suspension and debarment status for 2 of 2 vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: MWCOG’s internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status is documented. Effect: Failure to verify and document the suspension and debarment status of vendors may result in MWCOG issuing payments to vendors that are suspended or debarred and not authorized to provide services under the program. Recommendation: MWCOG should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors. Views of responsible officials: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors.
Reference Number: 2023-001 Prior Year Finding: No Federal Agency: Pass-Through Agency: U.S. Department of Homeland Security Government of the District of Columbia Homeland Security and Emergency Management Agency Federal Program: Securing the Cities Program Assistance Listing Number: 97.106 Award Number and Year: 17STC117-02, 20STC117-01 (9/1/2021-8/31/2023) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: MWCOG did not determine the suspension and debarment status of vendors with expenditures exceeding $25,000 as required by federal regulations. Context: The suspension and debarment status for 2 of 2 vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: MWCOG’s internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status is documented. Effect: Failure to verify and document the suspension and debarment status of vendors may result in MWCOG issuing payments to vendors that are suspended or debarred and not authorized to provide services under the program. Recommendation: MWCOG should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors. Views of responsible officials: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors.
Reference Number: 2023-001 Prior Year Finding: No Federal Agency: Pass-Through Agency: U.S. Department of Homeland Security Government of the District of Columbia Homeland Security and Emergency Management Agency Federal Program: Securing the Cities Program Assistance Listing Number: 97.106 Award Number and Year: 17STC117-02, 20STC117-01 (9/1/2021-8/31/2023) Compliance Requirement: Suspension and Debarment Type of Finding: Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Compliance: 2 CFR 200.214 Suspension and Debarment restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. 2 CFR 180.300 states that an entity may determine suspension and debarment status by: (a) Checking SAM (System for Award Management) Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: MWCOG did not determine the suspension and debarment status of vendors with expenditures exceeding $25,000 as required by federal regulations. Context: The suspension and debarment status for 2 of 2 vendors was not documented. Questioned costs: There are no questioned costs related to this finding as the vendors were not federally suspended or debarred. Cause: MWCOG’s internal controls over suspension and debarment are not sufficient to ensure that all vendors’ suspension and debarment status is documented. Effect: Failure to verify and document the suspension and debarment status of vendors may result in MWCOG issuing payments to vendors that are suspended or debarred and not authorized to provide services under the program. Recommendation: MWCOG should ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors. Views of responsible officials: MWCOG will ensure that all vendors’ suspension and debarment status be documented in the procurement files at the time of contract with the vendors.