Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting
Grant Number & Year: SLFRP0923, March 3, 2021, through December 31, 2024
Federal Grantor Agency: U.S. Department of the Treasury
Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part:
The non-Federal entity must:
(a) 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).
The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following:
Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200.
The U.S. Department of the Treasury issued “Compliance and Reporting Guidance” and frequently asked questions, which specify the reporting requirements related to Coronavirus State and Local Fiscal Recovery Funds (CSLFRF).
A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such a plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission.
Condition: The County did not implement effective internal controls to ensure that the reporting requirements of the CSLFRF were completed accurately. The Project and Expenditure report submitted on April 1, 2024, did not contain accurate information for multiple expenditure and obligations categories.
Repeat Finding: No
Questioned Costs: None
Statistical Sample: No
Context: The following table summarizes the overall variances noted:
These variances were due to the following:
• A County Bridge Project was not included on this report. Current period obligations and current period expenditures for this project were $750,000.
• For the County’s Premium Pay project, the Project and Expenditures Report correctly reported current period obligations and current period expenditures of $49,787; however, the total cumulative obligations and the total cumulative expenditures for this project did not increase from the report submitted in the previous year.
Additionally, the County improperly reported $1,098 of expenditures under the Hometown Housing Project, when these expenditures were actually related to the Communications Update Project.
Aside from the issues noted above, the following reporting requirements were properly completed:
• Obligations and expenditures were accurately reported for five of the County’s nine projects.
• All projects were reported under the correct project expenditure category and subcategory.
• The total amount received was accurately reported.
• The report was submitted timely.
Cause: Lack of procedures and knowledge relating to Federal reporting requirements.
Effect: Inaccurate information was reported to the U.S. Department of the Treasury on the 2024 Project and Expenditure report. Additionally, there is an increased risk of the County not complying with the reporting requirements set by the U.S Department of the Treasury.
Recommendation: We recommend the County implement procedures to ensure Federal reporting requirements are completed accurately. Such procedures could include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report.
View of Officials: The County will implement procedures to ensure reporting is completed correctly.
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment
Grant Number & Year: SLFRP0923, March 3, 2021, through December 31, 2024
Federal Grantor Agency: U.S. Department of the Treasury
Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part:
The non-Federal entity must:
(a) 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).
2 CFR § 200.214 (January 1, 2024) states the following:
Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following:
Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200.
2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . .[entity].”
A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented.
Condition: The County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented.
We noted that the County used CSLFRF to pay three vendors over $25,000 each, totaling $1,294,743, during the fiscal year ended June 30, 2024. The County was unable to support that a review was performed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions.
We reviewed SAM.gov (the “System for Award Management,” an official website of the U.S. Government) and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed.
Repeat Finding: 2023-002
Questioned Costs: None
Statistical Sample: No
Context: The following table provides details of the covered transactions noted:
Cause: Lack of procedures and knowledge regarding suspension and debarment requirements.
Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions.
Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented.
View of Officials: Saline County will set up procedures to ensure reviews are performed to ensure vendors are not excluded or disqualified (SAM).
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting
Grant Number & Year: SLFRP0923, March 3, 2021, through December 31, 2024
Federal Grantor Agency: U.S. Department of the Treasury
Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part:
The non-Federal entity must:
(a) 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).
The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following:
Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200.
The U.S. Department of the Treasury issued “Compliance and Reporting Guidance” and frequently asked questions, which specify the reporting requirements related to Coronavirus State and Local Fiscal Recovery Funds (CSLFRF).
A good internal control plan includes establishing effective internal controls through written policies and procedures to ensure Federal reporting requirements are completed accurately. Such a plan should include, among other things, appropriate training on Federal reporting requirements and require a documented, detailed review of each report to be completed by a knowledgeable individual, who did not prepare the report, prior to submission.
Condition: The County did not implement effective internal controls to ensure that the reporting requirements of the CSLFRF were completed accurately. The Project and Expenditure report submitted on April 1, 2024, did not contain accurate information for multiple expenditure and obligations categories.
Repeat Finding: No
Questioned Costs: None
Statistical Sample: No
Context: The following table summarizes the overall variances noted:
These variances were due to the following:
• A County Bridge Project was not included on this report. Current period obligations and current period expenditures for this project were $750,000.
• For the County’s Premium Pay project, the Project and Expenditures Report correctly reported current period obligations and current period expenditures of $49,787; however, the total cumulative obligations and the total cumulative expenditures for this project did not increase from the report submitted in the previous year.
Additionally, the County improperly reported $1,098 of expenditures under the Hometown Housing Project, when these expenditures were actually related to the Communications Update Project.
Aside from the issues noted above, the following reporting requirements were properly completed:
• Obligations and expenditures were accurately reported for five of the County’s nine projects.
• All projects were reported under the correct project expenditure category and subcategory.
• The total amount received was accurately reported.
• The report was submitted timely.
Cause: Lack of procedures and knowledge relating to Federal reporting requirements.
Effect: Inaccurate information was reported to the U.S. Department of the Treasury on the 2024 Project and Expenditure report. Additionally, there is an increased risk of the County not complying with the reporting requirements set by the U.S Department of the Treasury.
Recommendation: We recommend the County implement procedures to ensure Federal reporting requirements are completed accurately. Such procedures could include, among other things, appropriate training on Federal reporting requirements and a documented review by a knowledgeable individual who was not involved in the preparation of the report.
View of Officials: The County will implement procedures to ensure reporting is completed correctly.
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension & Debarment
Grant Number & Year: SLFRP0923, March 3, 2021, through December 31, 2024
Federal Grantor Agency: U.S. Department of the Treasury
Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR) § 200.303 (January 1, 2024) states the following, in relevant part:
The non-Federal entity must:
(a) 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).
2 CFR § 200.214 (January 1, 2024) states the following:
Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
The U.S. Department of the Treasury adopted the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 1000.10 (January 1, 2024), which states the following:
Except for the deviations set forth elsewhere in this Part, the Department of the Treasury adopts the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, set forth at 2 CFR part 200.
2 CFR § 180.300 (January 1, 2024) requires non-Federal entities to verify that an entity is not excluded or disqualified prior to entering into a covered transaction by “(a) Checking SAM Exclusions; or (b) Collecting a certification from that . . . [entity]; or (c) Adding a clause or condition to the covered transaction with that . . .[entity].”
A good internal control plan requires the County to have proper procedures in place to verify that contractors paid with Federal funds are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented.
Condition: The County could not provide documentation to support that the County implemented effective internal controls to ensure that suspension and debarment requirements were followed and adequately documented.
We noted that the County used CSLFRF to pay three vendors over $25,000 each, totaling $1,294,743, during the fiscal year ended June 30, 2024. The County was unable to support that a review was performed to ensure that these vendors were not excluded or disqualified prior to entering into these covered transactions.
We reviewed SAM.gov (the “System for Award Management,” an official website of the U.S. Government) and noted that none of these vendors were suspended, debarred, or otherwise excluded from participation in Federal programs or activities as of the date testing was performed.
Repeat Finding: 2023-002
Questioned Costs: None
Statistical Sample: No
Context: The following table provides details of the covered transactions noted:
Cause: Lack of procedures and knowledge regarding suspension and debarment requirements.
Effect: Without adequate procedures to ensure contractors are not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, there is an increased risk for the misuse of Federal funds and noncompliance with Federal regulations, leading to possible Federal sanctions.
Recommendation: We recommend the County implement procedures to ensure, prior to entering into a covered transaction, that a contractor is not suspended, debarred, or otherwise excluded from or ineligible for participation in Federal programs or activities, and those procedures are adequately documented.
View of Officials: Saline County will set up procedures to ensure reviews are performed to ensure vendors are not excluded or disqualified (SAM).