Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-003 – Fiscal Management (Material Weakness)
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Cash Management
Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for
the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs
under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results
of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329.
Condition: During portions of the fiscal year, the District prepared reimbursement calculations relying on an internally
developed spreadsheet tool, rather than using amounts solely obtained from the general ledger and supporting
documentation. The reimbursement reports were prepared by management with limited review. Conflicts over review
and other monitoring procedures occurred, and were not always resolved. Complete supporting documentation
for the claimed costs were not always available. Claims and other financial reports due to ODOT were regularly
submitted after the due dates. The late and/or unsubstantiated filings have resulted in lost claims for the District,
and potential refunding of reimbursements received.
Cause: Internal control procedures assuring timely and accurate preparation of reports and filing of the reimbursement
requests were not designed or implemented adequately. Maintaining sufficient and accurate supporting documentation
for each report was not possible because original data was not relied upon by management, to complete
the reports and reimbursement requests.
Effect or Potential Effect: The lack of effective internal control activities over cash management, including financial
reporting, allowed for reporting and claims errors, from simple calculation errors to requests for reimbursements
of unauthorized purposes. Improper financial reporting to the ODOT occurred regularly. Lack of timely filing of
reimbursement requests for amounts claimed, resulted in lost revenues and claims that may be required to be returned.
Questioned Cost: No
Context: Delays in filing reimbursement claims, delays in filing financial reports to ODOT, and internal disputes
regarding completion of grant reimbursement request procedures were evident. Weak or nonexistent controls over
cash management, including fiscal management, may result in lost revenues and risks of creating unnecessary liabilities
in the form of refunds due to ODOT.
Repeat of a Prior-Year Finding: Yes
Recommendation: The District should design and implement internal control policies and procedures for cash
management, including fiscal management and financial reporting. Monitoring, information and communication
control activities should also be designed and implemented as part of the effort the reduce the risk of continued
matters of noncompliance related to cash management.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s General Manager resigned effective September 13, 2024. The Board has
adopted a plan to procure qualified professional assistance to evaluate and restructure the organization and assist in
daily management activities until a new General Manager can be hired and trained. Additional assistance for resolving
these deficiencies has been offered by ODOT and accepted by the Board.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District
Finding 2024-004 - Procurement (Material Weakness)
CFDA Title and Number: 20.526 Grants for Buses and Bus Facilities Formula Program
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors & Individuals with Disabilities.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
CFDA Title and Number: 20.509 (5311) Operating Assistance. Formula Grants for Rural.
Name of Federal Agency: Department of Transportation
Internal Control over Compliance: Procurement
Criteria: 2 CFR Part 200.318(a-k) Numerous procurement regulations exist requiring federal grant awardees to
develop and implement internal control policies and procedures related to procurement activities.
Condition: The District made expenditures and engaged in contracts without following relevant procurement requirements.
Cause: Management lacked awareness of relevant procurement regulations. Consequently, no internal control policies
or procedures related to procurement existed, or policies and procedures existed but were not implemented.
Effect or Potential Effect: The lack of effective internal controls over procurement activities allowed for widespread
deficiencies and noncompliant activities, which resulted in the District’s revocation of one award.
Questioned Cost: No
Context: Without proper procurement policies and procedures, the risk of compliance requirement violations is
significant. The District failed to meet numerous procurement requirements throughout the year, and ultimately lost
a significant award for bus acquisitions.
Repeat of a Prior-Year Finding: No
Recommendation: The District should design and implement internal controls related to procurement regulations
that will reduce the risk that the District’s procurement activities are not in compliance with federal regulations.
District's Response: The District acknowledges the weaknesses and its intention of correcting weaknesses.
Corrective Action Plan: The District’s shall design and implement, or revise, policies and procedures for meeting
procurement compliance requirements. The District will work with ODOT to ensure compliance. The new procurement
policy must include not only policies for procurements, but also for documentation of solicitations, contracts
activities.
Planned Implementation Date: September 30, 2024
Responsible Persons: District Board, Umpqua Public Transit District