2023 – 001
Federal Agency: U.S. Department of Agriculture
Federal Program Name: Rural eConnectivity Pilot Program
Assistance Listing Number: 10.752
Federal Award Identification Number and Year: MD 1701-A64, 2020
Award Period: July 1, 2020 – July 1, 2025
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: Per 2CFR § 200.303(a), nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal 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 be in compliance 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).
COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” Management review controls are defined as, “the activities of a person, different than the preparer, through analyzing and performing oversight of activities performed, and is an integral part of any internal control structure.”
Questioned Costs: None
Condition/Context: The Commission did not maintain evidence of the approval of inventory expenditures charged to the grant for the first eight months of fiscal year ended June 30, 2023.
Cause: The Commission did not have sufficient policies and procedures over internal controls to maintain evidence of review and approval of inventory expenditures are properly documented until March 2023.
Effect: Inventory expenditures may be charged to the grant that are not eligible.
Repeat Finding: This is a repeat finding.
Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented.
Views of Responsible Officials: Management agrees with the finding.
2023 – 002
Federal Agency: U.S. Department of Agriculture
Federal Program Name: Rural eConnectivity Pilot Program
Assistance Listing Number: 10.752
Federal Award Identification Number and Year: MD 1701-A64, 2020
Award Period: July 1, 2020 – July 1, 2025
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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.
Questioned Costs: None
Condition/Context: One of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred.
Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds.
Effect: The Commission could make a disbursement to a vendor that is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds.
Views of Responsible Officials: Management agrees with the finding.
2023 – 003
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: MD-0044 and 2021
Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: When a nonfederal 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.
Questioned Costs: None
Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred.
Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds.
Effect: The Commission could make a disbursement to a vendor that is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds.
Views of Responsible Officials: Management agrees with the finding.
2023 – 003
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: MD-0044 and 2021
Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: When a nonfederal 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.
Questioned Costs: None
Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred.
Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds.
Effect: The Commission could make a disbursement to a vendor that is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds.
Views of Responsible Officials: Management agrees with the finding.
2023 – 001
Federal Agency: U.S. Department of Agriculture
Federal Program Name: Rural eConnectivity Pilot Program
Assistance Listing Number: 10.752
Federal Award Identification Number and Year: MD 1701-A64, 2020
Award Period: July 1, 2020 – July 1, 2025
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: Per 2CFR § 200.303(a), nonfederal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal 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 be in compliance 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).
COSO/Internal Control Framework defines control activities as “policies and procedures that help ensure management’s directives are carried out.” Management review controls are defined as, “the activities of a person, different than the preparer, through analyzing and performing oversight of activities performed, and is an integral part of any internal control structure.”
Questioned Costs: None
Condition/Context: The Commission did not maintain evidence of the approval of inventory expenditures charged to the grant for the first eight months of fiscal year ended June 30, 2023.
Cause: The Commission did not have sufficient policies and procedures over internal controls to maintain evidence of review and approval of inventory expenditures are properly documented until March 2023.
Effect: Inventory expenditures may be charged to the grant that are not eligible.
Repeat Finding: This is a repeat finding.
Recommendation: We recommend the Commission continue with established policies and procedures implemented in March 2023 over internal controls to ensure review and approval of inventory expenditures are properly documented.
Views of Responsible Officials: Management agrees with the finding.
2023 – 002
Federal Agency: U.S. Department of Agriculture
Federal Program Name: Rural eConnectivity Pilot Program
Assistance Listing Number: 10.752
Federal Award Identification Number and Year: MD 1701-A64, 2020
Award Period: July 1, 2020 – July 1, 2025
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: When a nonfederal entity enters into a covered transaction with an entity at a lower tier, the nonfederal 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.
Questioned Costs: None
Condition/Context: One of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred.
Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds.
Effect: The Commission could make a disbursement to a vendor that is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds.
Views of Responsible Officials: Management agrees with the finding.
2023 – 003
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: MD-0044 and 2021
Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: When a nonfederal 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.
Questioned Costs: None
Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred.
Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds.
Effect: The Commission could make a disbursement to a vendor that is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds.
Views of Responsible Officials: Management agrees with the finding.
2023 – 003
Federal Agency: U.S. Department of Treasury
Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Award Identification Number and Year: MD-0044 and 2021
Award Period: March 11, 2021 through December 31, 2024, liquidated by December 31, 2026
Type of Finding: Significant Deficiency in Internal Control over Compliance
Criteria or Specific Requirement: When a nonfederal 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.
Questioned Costs: None
Condition/Context: Four of five vendors tested did not have proper documentation maintained to support suspension and debarment verification was performed prior to them being paid with federal funds. Per SAM.gov, there was no history of the vendor being suspended or debarred.
Cause: The Commission’s policies and procedures did not require documentation be maintained to verify vendors are not suspended or debarred prior to paying with Federal grant funds.
Effect: The Commission could make a disbursement to a vendor that is suspended or debarred.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Commission review its policies and procedures to require documentation be maintained to verify vendors are not suspended or debarred prior to being paid with federal funds.
Views of Responsible Officials: Management agrees with the finding.