U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID 19 – Coronavirus State and Local Fiscal Recovery Funds
Procurement
Material Noncompliance
Material Weakness in Internal Control
Criteria: As a condition of receiving Federal awards, non-Federal entities agree to comply with
laws, regulations, and the provisions of grant agreements and contracts, and to maintain
internal control to provide reasonable assurance of compliance with these requirements.
Prior to entering a covered transaction, a non-federal entity must ensure the vendor was not
suspended, debarred, or otherwise excluded. A contract award must not be made to parties
listed on the governmentwide exclusions in the System for Award Management (SAM), in
accordance with the OMB guidelines at 2 CFR 180. Further, 2 CFR section Appendix II to Part
200, Contract Provisions for Non-Federal Entity Contracts Under Federal Awards states that in
addition to other provisions required by the Federal agency or non-Federal entity, all contracts
made by the non-Federal entity under the Federal award must contain certain provisions, as
applicable. Finally, the procurement method used must be appropriate based on the dollar
amount and conditions specified in 2 CFR section 200.320. The procurement file must contain
evidence that supports the rationale for the method of procurement, selection of the contract
type, basis for contractor selection, and basis of contract price.
Condition: The County was not able to provide evidence that they verified the vendors used in
the program were not suspended, debarred, or otherwise excluded prior to entering the
contract for 2 of 2 vendors tested. The County also failed to provide certain provisions required
by the Uniform Guidance in the contracts with both vendors specifically for the Davis Bacon Act
and the Equal Employment Opportunity provisions.
The County was not able to provide evidence to support the rationale for the method of
procurement, for 1 of 2 vendors testing. This included whether the procurement method was
appropriate, whether it provided for full and open competition, or if a cost/price analysis was
performed.
Cause: Due to the County’s failure to understand the procurement requirements the
procurement files did not contain the required information to support compliance with the
standards.
Effect: Insufficient procedures and internal controls related to procurement resulted in a finding.
13
14
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Questioned Costs: None to report
Context/Sampling: The population consisted of 3 vendors, 2 of which were selected for procurement,
suspension and debarment testing.
Repeat Finding from Prior Year(s): No
Recommendation: We recommend the County modify and strengthen its current policies and
procedures to ensure documentation is retained regarding verification of vendor suspension/debarment,
selection of procurement method in accordance with 2 CFR section 200.320 and that all applicable
required provisions are communicated to contractors in accordance with 2 CFR Appendix II to Part 200.
Views of Responsible Officials: Agree
U.S. Department of Treasury
Passed-through the Colorado Department of Local Affairs
FFAL #21.027
COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Subrecipient Monitoring
Material Noncompliance
Material Weakness in Internal Controls
Criteria: Section 2 CFR 200.331 establishes the determination of whether there is a subrecipient
or contractor of the federal award. The non-Federal entity may concurrently receive Federal
awards as a recipient, a subrecipient, and a contractor, depending on the substance of its
agreements with Federal awarding agencies and pass-through entities. Therefore, a passthrough
entity must make case-by-case determinations whether each agreement it makes for
the disbursement of Federal program funds casts the party receiving the funds in the role of a
subrecipient or a contractor. The Federal awarding agency may supply and require recipients to
comply with additional guidance to support these determinations provided such guidance does
not conflict with this section. Once it is determined the recipient is a sub-recipient there are
certain requirements for pass-through entities established in 2 CFR 200.332.
Per 2 CFR 200.332, pass-through entities are responsible for informing subrecipients of the
Federal award identifiers including but not limited to award date, period of performance and
Federal awarding agency and Assistance Listing Number and title. Pass-through entities are
required to assess the subrecipient’s risk of noncompliance with Federal statutes, regulations
and the terms and conditions of the subaward. Further, the pass-through entity is required to
perform certain monitoring activities to ensure the subaward is used for authorized purposes, in
compliance with Federal statutes, regulations, and the terms and conditions of the subaward;
and that subaward performance goals are achieved. Finally, the pass-through entity should also
verify the subrecipient is audited as required by Subpart F - Audit Requirement under the
Uniform Guidance. The monitoring policy should include an initial valuation of risk of
noncompliance to determine the appropriate level of monitoring required related to the
subaward as well as appropriate awarding documentation.
Condition: The County did not appropriately identify two subrecipients of the grant and initially
determined them to be contractors. The County failed to perform any subrecipient monitoring
as required by the Uniform Guidance.
Cause: Due to the County’s failure to understand the sub-recipient monitoring requirements,
two of subawards were incorrectly identified as contractors and none of the required award and
monitoring procedures were performed for the four subrecipients of the grant.
Effect: Insufficient procedures and internal controls related to subrecipients resulted in
noncompliance.
Questioned Costs: No questioned costs were identified as a result of our procedures.
16
Summit County, Colorado
Schedule of Findings and Questioned Costs
Year Ended December 31, 2023
Context/Sampling: All four subrecipients were selected for subrecipient monitoring testing.
Repeat Finding from Prior Years: No.
Recommendation: We recommend that the County establish and adhere to policies and
procedures, including internal controls, to ensure compliance with subrecipient monitoring
requirements as established by 2 CFR 200.331 and 2 CFR 200.332.
Views of Responsible Officials: Management agrees with the finding.