2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-002 Unrecorded Deposits (Material Weakness)
Federal Agency: Department of Homeland Security
Pass-through Agency: N/A
Cluster/Program: Staffing for Adequate Fire and Emergency Response (SAFER)
Assistance Listing Number: 97.083
Passed-through Identification: EMW-2020-FF-00046
Compliance Requirement: Cash Management
Type of Finding:
Internal Control over Compliance – Material Weakness
Material Noncompliance
Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Proper financial management and internal controls should ensure that all transactions related to Federal grants, including revenue recognition, expenditure tracking, and reporting, are accurately recorded in the Town’s general ledger in a timely manner. Failure to record deposits properly may result in financial misstatements, impact budgetary decisions, and affect compliance with Federal grant requirements.
Condition: During the audit, we identified that the Town did not record deposits related to reimbursement requests #18 and #19 in the general ledger. These deposits, totaling $132,701, were reimbursements for payroll expenses associated with the firefighters hired under the SAFER grant.
The unrecorded deposits caused the general ledger to be misstated as of June 30, 2024.
Cause: The Town does not have adequate internal controls to ensure that all cash receipts, particularly those related to federal programs are recorded in the general ledger in a timely manner. This appears to stem from lack of detailed oversight over the cash reconciliation process while there was turnover in the finance office.
Effect: Failure to record $132,701 in deposits resulted in a misstatement in the Town’s financial statements and non-compliance with cash management requirements. Additionally, the lack of timely recorded increases the risk of undetected errors or misuse of funds.
Questioned Costs: None. While the deposits cleared the Town’s operating bank account via ACH from the federal awarding agency, the Town eventually identified the missing deposits and posted them to their general ledger system.
Identification as Repeat Finding: This is not a repeat finding from the prior year.
Recommendation: We recommend that the Town implement procedures to ensure that all grant related deposits are recorded in the general ledger upon receipt. In addition, we recommend that the Town implement additional procedures during the reconciliation process to ensure any identified variances or discrepancies are researched and addressed in a timely manner.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Verification of Suspension and Debarment (Material Weakness)
Federal Agency: Department of Homeland Security
Pass-through Agency: N/A
Cluster/Program: Staffing for Adequate Fire and Emergency Response (SAFER)
Assistance Listing Number: 97.083
Passed-through Identification: EMW-2020-FF-00046
Compliance Requirement: Suspension and Debarment
Type of Finding:
Internal Control over Compliance – Material Weakness
Material Noncompliance
Criteria or Specific Requirement: In accordance with 2 CFR 180.300, recipients of federal funds are required to ensure that contractors, subcontractors, vendors, or persons are not suspended or debarred from participating in federal programs before awarding any contract or procurement that exceeds $25,000. This verification must be conducted through the System for Award Management (SAM) or equivalent records.
Additionally, the grant award letter explicitly required compliance with non-procurement suspension and debarment requirements, reinforcing the Town’s obligation to verify the eligibility status of individuals and entities receiving federal funds.
Condition: During our review of the Town’s suspension and debarment process, we noted that the Town hired firefighters for federally funded positions without verifying whether the employees were suspended or debarred prior to the execution of their contracts, as required by federal regulations and the grant’s terms. No evidence was provided demonstrating that the Town checked the SAM.gov website, collected a certification, or included a clause or condition for each employee.
Cause: The Town’s hiring procedures did not include a formalized step to verify the suspension or debarment status of employees hired under federally funded positions before their contracts were executed. Additionally, there was no established policy or internal control requiring verification through the System for Award Management (SAM), obtaining a self-certification from the employee, or incorporating a suspension/debarment clause in employment agreements. The absence of these procedures resulted in noncompliance with federal regulations and grant requirements.
Effect: Failure to verify the suspension or debarment status of federally funded hires increases the risk of noncompliance with 2 CFR 180.300 and the grant’s terms, potentially resulting in cost disallowance, repayment of federal funds, penalties, and heightened scrutiny from oversight agencies.
Questioned Costs: $1,025,583, which represents total amount paid in fiscal year 2024.
Identification as Repeat Finding: This is not a repeat finding from the prior year.
Recommendation: We recommend that the Town establish a formalized process to verify whether federal funds used for payroll are subject to non-procurement suspension and debarment requirements. If such a requirement applies, the Town must ensure compliance by implementing appropriate verification procedures before hiring individuals for federally funded positions.
To meet the requirements of 2 CFR 180.300, the Town should verify suspension and debarment status by either checking the SAM.gov database, obtaining a certification from the employee, or including a suspension and debarment clause in employment contracts requiring employees to certify their eligibility. Additionally, the Town should document compliance efforts for audit purposes and consider incorporating this requirement into its hiring policies and procedures to prevent future instances of noncompliance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-001 Document Policies and Procedures over Federal Awards (Significant Deficiency)
Cluster/Program: All Federal Programs
Type of Finding:
Compliance – Other Matters
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement: OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) established significant requirements related to Federal awards. The requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Conflict of interest
• Employee travel
• Cash Management
• Equipment and inventory
• Procurement and Suspension and Debarment
• Time and effort reporting; and
• Subrecipient monitoring and management.
Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Condition: The Town has not formalized written policies and procedures related to Federal awards as required under Uniform Guidance.
Cause: Weaknesses in the formal documentation of internal controls.
Effect: There are no formal policies related to federal grant activity noted above.
Questioned Costs: There are no questioned costs because of this finding as there are no costs directly associated with this compliance requirement.
Identification as Repeat Finding: This is not a repeat finding.
Recommendation: The Town should ensure that written policies and procedures are compiled and adopted as soon as practicable to ensure compliance with the Uniform Guidance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-002 Unrecorded Deposits (Material Weakness)
Federal Agency: Department of Homeland Security
Pass-through Agency: N/A
Cluster/Program: Staffing for Adequate Fire and Emergency Response (SAFER)
Assistance Listing Number: 97.083
Passed-through Identification: EMW-2020-FF-00046
Compliance Requirement: Cash Management
Type of Finding:
Internal Control over Compliance – Material Weakness
Material Noncompliance
Criteria or Specific Requirement: Federal regulations 2 CFR 200.303 states, the Town, as a recipient of Federal funds, must establish and maintain effective internal controls 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.
Proper financial management and internal controls should ensure that all transactions related to Federal grants, including revenue recognition, expenditure tracking, and reporting, are accurately recorded in the Town’s general ledger in a timely manner. Failure to record deposits properly may result in financial misstatements, impact budgetary decisions, and affect compliance with Federal grant requirements.
Condition: During the audit, we identified that the Town did not record deposits related to reimbursement requests #18 and #19 in the general ledger. These deposits, totaling $132,701, were reimbursements for payroll expenses associated with the firefighters hired under the SAFER grant.
The unrecorded deposits caused the general ledger to be misstated as of June 30, 2024.
Cause: The Town does not have adequate internal controls to ensure that all cash receipts, particularly those related to federal programs are recorded in the general ledger in a timely manner. This appears to stem from lack of detailed oversight over the cash reconciliation process while there was turnover in the finance office.
Effect: Failure to record $132,701 in deposits resulted in a misstatement in the Town’s financial statements and non-compliance with cash management requirements. Additionally, the lack of timely recorded increases the risk of undetected errors or misuse of funds.
Questioned Costs: None. While the deposits cleared the Town’s operating bank account via ACH from the federal awarding agency, the Town eventually identified the missing deposits and posted them to their general ledger system.
Identification as Repeat Finding: This is not a repeat finding from the prior year.
Recommendation: We recommend that the Town implement procedures to ensure that all grant related deposits are recorded in the general ledger upon receipt. In addition, we recommend that the Town implement additional procedures during the reconciliation process to ensure any identified variances or discrepancies are researched and addressed in a timely manner.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.
2024-003 Verification of Suspension and Debarment (Material Weakness)
Federal Agency: Department of Homeland Security
Pass-through Agency: N/A
Cluster/Program: Staffing for Adequate Fire and Emergency Response (SAFER)
Assistance Listing Number: 97.083
Passed-through Identification: EMW-2020-FF-00046
Compliance Requirement: Suspension and Debarment
Type of Finding:
Internal Control over Compliance – Material Weakness
Material Noncompliance
Criteria or Specific Requirement: In accordance with 2 CFR 180.300, recipients of federal funds are required to ensure that contractors, subcontractors, vendors, or persons are not suspended or debarred from participating in federal programs before awarding any contract or procurement that exceeds $25,000. This verification must be conducted through the System for Award Management (SAM) or equivalent records.
Additionally, the grant award letter explicitly required compliance with non-procurement suspension and debarment requirements, reinforcing the Town’s obligation to verify the eligibility status of individuals and entities receiving federal funds.
Condition: During our review of the Town’s suspension and debarment process, we noted that the Town hired firefighters for federally funded positions without verifying whether the employees were suspended or debarred prior to the execution of their contracts, as required by federal regulations and the grant’s terms. No evidence was provided demonstrating that the Town checked the SAM.gov website, collected a certification, or included a clause or condition for each employee.
Cause: The Town’s hiring procedures did not include a formalized step to verify the suspension or debarment status of employees hired under federally funded positions before their contracts were executed. Additionally, there was no established policy or internal control requiring verification through the System for Award Management (SAM), obtaining a self-certification from the employee, or incorporating a suspension/debarment clause in employment agreements. The absence of these procedures resulted in noncompliance with federal regulations and grant requirements.
Effect: Failure to verify the suspension or debarment status of federally funded hires increases the risk of noncompliance with 2 CFR 180.300 and the grant’s terms, potentially resulting in cost disallowance, repayment of federal funds, penalties, and heightened scrutiny from oversight agencies.
Questioned Costs: $1,025,583, which represents total amount paid in fiscal year 2024.
Identification as Repeat Finding: This is not a repeat finding from the prior year.
Recommendation: We recommend that the Town establish a formalized process to verify whether federal funds used for payroll are subject to non-procurement suspension and debarment requirements. If such a requirement applies, the Town must ensure compliance by implementing appropriate verification procedures before hiring individuals for federally funded positions.
To meet the requirements of 2 CFR 180.300, the Town should verify suspension and debarment status by either checking the SAM.gov database, obtaining a certification from the employee, or including a suspension and debarment clause in employment contracts requiring employees to certify their eligibility. Additionally, the Town should document compliance efforts for audit purposes and consider incorporating this requirement into its hiring policies and procedures to prevent future instances of noncompliance.
Views of Responsible Officials: Management’s views and corrective action plan is included at the end of this report.