Condition: Hill County is responsible for complying with Uniform Guidance and the Suspension and Debarment compliance requirement as required by the contract and federal award documents for ARPA funds.
Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300.
Context: In reviewing contract HC 22-120, the County was unable to provide proof that, prior to entering the contract, the County verified the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300.
Cause: The County’s Procurement Policy does not address Suspension and Debarment when performed internally rather than by a third party.
Effect: Contractors may be suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, thus putting the County out of compliance with the federal award.
Recommendation: Prior to entering into any subawards and contracts with award funds, the County should verify the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, and document accordingly.
Planned Corrective Action: “The County spoke with all the grant coordinators communicating this requirement. The County is aware to check all new contractors. They have requested the information from contractors. The Procurement Policy is under review at this time. The County Attorney issued a statement about the process.”
Condition: Hill County is responsible for complying with Uniform Guidance and all compliance requirements as required by the contract and federal award documents for reimbursement grants, as it relates to recording of the related award expenditures.
Criteria: Prior to payment of expenditures with award funds, recipients must verify proper account and fund recording, pursuant to 2 CFR section 200.500.
Context: In reviewing and compiling the federal award expenditures for testing, we noted the County posted several journal voucher entries to change the original recording of numerous expenditures, either to record as ARPA expenditures or to remove as ARPA expenditures to another fund and/or award. In addition, several expenditures were only partially applied to ARPA with the rest applied to other funding sources, but were not segregated as such in the accounting system.
Cause: There appears to be confusion between departments in which expenditures are to be coded as ARPA and which are not. County personnel should utilize approved project budgets in order to have the accounting and financial records properly recorded and reflected at the time of the transaction. County personnel should also clearly record any transactions that are covered by multiple funding sources as such.
Effect: Expenditures may be submitted for reimbursement more than once, or to more than a single grant award, thus putting the County out of compliance with the federal award and potentially resulting in a duplication in funding.
Recommendation: Prior to payment of expenditures with award funds, the County should closely monitor the expenditures as compared to each project budget and verify the expenditures are properly recorded to the appropriate award, pursuant to 2 CFR section 200.500, and document accordingly. Any subsequent change recorded via a journal voucher entry should also be properly documented and approved.
Planned Corrective Action: “The coding of the invoices has improved. There is a detailed list of how each vendor should be coded. There are still times invoices need to transfer to a different fund in order to utilize the funding more efficiently. The grant coordinator has discussed everything. The transfers that are done have already been approved and paid. The expenditures are transferred to match the grant coordinator. Expenditure transfers can be done if the expenditure was incorrectly coded.”
Condition: Hill County is responsible for complying with Uniform Guidance and the Suspension and Debarment compliance requirement as required by the contract and federal award documents for ARPA funds.
Criteria: Prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300.
Context: In reviewing contract HC 22-120, the County was unable to provide proof that, prior to entering the contract, the County verified the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300.
Cause: The County’s Procurement Policy does not address Suspension and Debarment when performed internally rather than by a third party.
Effect: Contractors may be suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, thus putting the County out of compliance with the federal award.
Recommendation: Prior to entering into any subawards and contracts with award funds, the County should verify the contractor was not suspended, debarred, or otherwise excluded pursuant to 21 CFR section 19.300, and document accordingly.
Planned Corrective Action: “The County spoke with all the grant coordinators communicating this requirement. The County is aware to check all new contractors. They have requested the information from contractors. The Procurement Policy is under review at this time. The County Attorney issued a statement about the process.”
Condition: Hill County is responsible for complying with Uniform Guidance and all compliance requirements as required by the contract and federal award documents for reimbursement grants, as it relates to recording of the related award expenditures.
Criteria: Prior to payment of expenditures with award funds, recipients must verify proper account and fund recording, pursuant to 2 CFR section 200.500.
Context: In reviewing and compiling the federal award expenditures for testing, we noted the County posted several journal voucher entries to change the original recording of numerous expenditures, either to record as ARPA expenditures or to remove as ARPA expenditures to another fund and/or award. In addition, several expenditures were only partially applied to ARPA with the rest applied to other funding sources, but were not segregated as such in the accounting system.
Cause: There appears to be confusion between departments in which expenditures are to be coded as ARPA and which are not. County personnel should utilize approved project budgets in order to have the accounting and financial records properly recorded and reflected at the time of the transaction. County personnel should also clearly record any transactions that are covered by multiple funding sources as such.
Effect: Expenditures may be submitted for reimbursement more than once, or to more than a single grant award, thus putting the County out of compliance with the federal award and potentially resulting in a duplication in funding.
Recommendation: Prior to payment of expenditures with award funds, the County should closely monitor the expenditures as compared to each project budget and verify the expenditures are properly recorded to the appropriate award, pursuant to 2 CFR section 200.500, and document accordingly. Any subsequent change recorded via a journal voucher entry should also be properly documented and approved.
Planned Corrective Action: “The coding of the invoices has improved. There is a detailed list of how each vendor should be coded. There are still times invoices need to transfer to a different fund in order to utilize the funding more efficiently. The grant coordinator has discussed everything. The transfers that are done have already been approved and paid. The expenditures are transferred to match the grant coordinator. Expenditure transfers can be done if the expenditure was incorrectly coded.”