Finding 2023-006 – Lack of County-Wide Internal Controls Over Major Federal Program – Coronavirus
State and Local Fiscal Recovery Funds (Repeat Finding – 2022-006)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; Subrecipient Monitoring QUESTIONED COSTS: $0
Condition: Through the process of gaining an understanding of the County’s internal control
structure, it was noted that county-wide internal controls regarding Control Environment, Risk
Assessment, Information and Communication, and Monitoring have not been designed.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure the
County complies with grant requirements.
Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of
a breakdown in control activities which could result in unrecorded transactions, undetected errors,
or misappropriation of funds. Further, this condition could result in noncompliance with grant
requirements and a loss of federal funds.
Recommendation: OSAI recommends that the County design and implement a system of internal control
procedures to ensure compliance with grant requirements. This documentation should outline the
importance of internal controls, the risk that the County has identified, the control activities
established to address the risk, the steps taken to properly communicate pertinent information in a
timely manner and the methodology to monitor the quality of performance over time. These procedures
should be written policies and procedures and could be included in the County’s policies and
procedures handbook.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work toward
assessing and identifying risks to design written county-wide controls.
Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states in part:
Definition of Internal Control
Internal control is a process effected by an entity’s oversight body, management, and other
personnel that provides reasonable assurance that the objectives of an entity will be achieved.
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System –
OV2.04 states in part:
Components, Principles, and Attributes
Control Environment - The foundation for an internal control system. It provides the discipline and
structure to help an entity achieve its objectives.
Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This
assessment provides the basis for developing appropriate risk responses.
Information and Communication - The quality information management and personnel
communicate and use to support the internal control system. Monitoring - Activities management establishes and operates to assess the quality of
performance over time and promptly resolve the findings of audits and other reviews.
Finding 2023-007 – Lack of Internal Controls Over Major Federal Program – Coronavirus State and
Local Fiscal Recovery Funds (Repeat Finding – 2022-007)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSSITANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; and Subrecipient Monitoring
QUESTIONED COSTS: $0
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that Comanche County has not established procedures to ensure compliance
with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting; and
Subrecipient Monitoring
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance to grant requirements and could
lead to a loss of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that Comanche County receives to ensure
that proper internal controls are implemented.
Criteria: 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to
grant contracts.
Finding 2023-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State
and Local Fiscal Recovery Funds (Repeat Finding – 2022-014)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0
Condition: In the review of fifty-five (55) expenditures for federal programs, five (5) instances
were noted where the expenditures were not correctly reported on the Coronavirus State and Local
Fiscal Recovery Funds compliance reports.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are properly reported in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance to grant requirements.
Recommendation: OSAI recommends the County gain an understanding of the requirements for this
program and implement internal controls to ensure compliance with these requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures
to ensure future compliance with all requirements of federal grants.
Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.)
reads as follows:
10. Reporting. All recipients of federal funds must complete financial, performance, and compliance
reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a
cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting
must be consistent with the definition of expenditures
pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with
appropriate accounting standards and principles.
In addition, where appropriate, your organization needs to establish controls to ensure completion
and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this
guidance for a full overview of recipient reporting responsibilities.
Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The
non-Federal entity must submit performance reports at the interval required by the Federal awarding
agency or pass-through entity to best inform improvements in program outcomes and productivity.
Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual
circumstances, for example where more frequent reporting is necessary for the effective monitoring
of the Federal award or could significantly affect program outcomes. Reports submitted annually by
the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after
the reporting period. Reports submitted quarterly or semiannually must be due no later than 30
calendar days after the reporting period. Alternatively, the Federal awarding agency or
pass-through entity may require annual reports before the anniversary dates of multiple year
Federal awards. The final performance report submitted by the non-Federal entity and/or
pass-through entity must be due no later than 120 calendar days after the period of performance end
date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after
the period of performance end date, all final performance reports as required by the terms and
conditions of the Federal award. See also § 200.344. If a justified request is submitted by a
non-Federal entity, the Federal agency may extend the due date
for any performance report.
Finding 2023-006 – Lack of County-Wide Internal Controls Over Major Federal Program – Coronavirus
State and Local Fiscal Recovery Funds (Repeat Finding – 2022-006)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; Subrecipient Monitoring QUESTIONED COSTS: $0
Condition: Through the process of gaining an understanding of the County’s internal control
structure, it was noted that county-wide internal controls regarding Control Environment, Risk
Assessment, Information and Communication, and Monitoring have not been designed.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure the
County complies with grant requirements.
Effect of Condition: Without an adequate system of county-wide controls, there is greater risk of
a breakdown in control activities which could result in unrecorded transactions, undetected errors,
or misappropriation of funds. Further, this condition could result in noncompliance with grant
requirements and a loss of federal funds.
Recommendation: OSAI recommends that the County design and implement a system of internal control
procedures to ensure compliance with grant requirements. This documentation should outline the
importance of internal controls, the risk that the County has identified, the control activities
established to address the risk, the steps taken to properly communicate pertinent information in a
timely manner and the methodology to monitor the quality of performance over time. These procedures
should be written policies and procedures and could be included in the County’s policies and
procedures handbook.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work toward
assessing and identifying risks to design written county-wide controls.
Criteria: The GAO Standards – Section 1 – Fundamental Concepts of Internal Control – OV1.01 states in part:
Definition of Internal Control
Internal control is a process effected by an entity’s oversight body, management, and other
personnel that provides reasonable assurance that the objectives of an entity will be achieved.
Additionally, GAO Standards – Section 2 – Establishing an Effective Internal Control System –
OV2.04 states in part:
Components, Principles, and Attributes
Control Environment - The foundation for an internal control system. It provides the discipline and
structure to help an entity achieve its objectives.
Risk Assessment - Assesses the risks facing the entity as it seeks to achieve its objectives. This
assessment provides the basis for developing appropriate risk responses.
Information and Communication - The quality information management and personnel
communicate and use to support the internal control system. Monitoring - Activities management establishes and operates to assess the quality of
performance over time and promptly resolve the findings of audits and other reviews.
Finding 2023-007 – Lack of Internal Controls Over Major Federal Program – Coronavirus State and
Local Fiscal Recovery Funds (Repeat Finding – 2022-007)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSSITANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Period of
Performance; Procurement and Suspension and Debarment; Reporting; and Subrecipient Monitoring
QUESTIONED COSTS: $0
Condition: During the process of documenting the County’s internal controls regarding federal
disbursements, we noted that Comanche County has not established procedures to ensure compliance
with the following compliance requirements: Activities Allowed or Unallowed; Allowable Costs/Cost
Principles; Period of Performance; Procurement and Suspension and Debarment; Reporting; and
Subrecipient Monitoring
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are made in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance to grant requirements and could
lead to a loss of federal funds to the County.
Recommendation: OSAI recommends the County gain an understanding of requirements for this program
and implement internal control procedures to ensure compliance with requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will work with all
County Officials to go over all grants and federal monies that Comanche County receives to ensure
that proper internal controls are implemented.
Criteria: 2 CFR § 200.303 Internal Controls (a) reads as follows: The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable
assurance that the non-Federal entity is managing the Federal award in compliance with Federal
statutes, regulations, and the terms and conditions of the Federal award. These internal controls
should be in compliance with guidance in “Standards for
Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of
Sponsoring Organizations of the Treadway Commission (COSO).
Further, accountability and stewardship should be overall goals in management's accounting of
federal funds. Internal controls should be designed to monitor compliance with laws and regulations
pertaining to
grant contracts.
Finding 2023-014 – Noncompliance with Reporting Requirements Over Federal Grant – Coronavirus State
and Local Fiscal Recovery Funds (Repeat Finding – 2022-014)
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Reporting
QUESTIONED COSTS: $0
Condition: In the review of fifty-five (55) expenditures for federal programs, five (5) instances
were noted where the expenditures were not correctly reported on the Coronavirus State and Local
Fiscal Recovery Funds compliance reports.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure
federal expenditures are properly reported in accordance with federal compliance requirements.
Effect of Condition: This condition could result in noncompliance to grant requirements.
Recommendation: OSAI recommends the County gain an understanding of the requirements for this
program and implement internal controls to ensure compliance with these requirements.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures
to ensure future compliance with all requirements of federal grants.
Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (10. Reporting.)
reads as follows:
10. Reporting. All recipients of federal funds must complete financial, performance, and compliance
reporting as required and outlined in Part 2 of this guidance. Expenditures may be reported on a
cash or accrual basis, as long as the methodology is disclosed and consistently applied. Reporting
must be consistent with the definition of expenditures
pursuant to 2 CFR 200.1. Your organization should appropriately maintain accounting records for compiling and reporting accurate, compliant financial data, in accordance with
appropriate accounting standards and principles.
In addition, where appropriate, your organization needs to establish controls to ensure completion
and timely submission of all mandatory performance and/or compliance reporting. See Part 2 of this
guidance for a full overview of recipient reporting responsibilities.
Further, 2 CFR § 200.329 Monitoring and Reporting Program Performance (c)(1) reads as follows: The
non-Federal entity must submit performance reports at the interval required by the Federal awarding
agency or pass-through entity to best inform improvements in program outcomes and productivity.
Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual
circumstances, for example where more frequent reporting is necessary for the effective monitoring
of the Federal award or could significantly affect program outcomes. Reports submitted annually by
the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after
the reporting period. Reports submitted quarterly or semiannually must be due no later than 30
calendar days after the reporting period. Alternatively, the Federal awarding agency or
pass-through entity may require annual reports before the anniversary dates of multiple year
Federal awards. The final performance report submitted by the non-Federal entity and/or
pass-through entity must be due no later than 120 calendar days after the period of performance end
date. A subrecipient must submit to the pass-through entity, no later than 90 calendar days after
the period of performance end date, all final performance reports as required by the terms and
conditions of the Federal award. See also § 200.344. If a justified request is submitted by a
non-Federal entity, the Federal agency may extend the due date
for any performance report.