Audit 352345

FY End
2024-06-30
Total Expended
$2.51M
Findings
6
Programs
18
Organization: Big Horn County (MT)
Year: 2024 Accepted: 2025-04-01

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
553758 2024-017 Material Weakness Yes P
553759 2024-018 Material Weakness Yes I
553760 2024-019 Material Weakness - M
1130200 2024-017 Material Weakness Yes P
1130201 2024-018 Material Weakness Yes I
1130202 2024-019 Material Weakness - M

Contacts

Name Title Type
E29AD46LK367 Mike Opie Auditee
4066559700 Curt Wyss Auditor
No contacts on file

Notes to SEFA

Title: NOTE 1 - BASIS OF PRESENTATION Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the schedule) includes the federal award activity of the government under programs of the federal government for the year ended June 30, 2024. The Information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of the Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the government, it is not intended to and does not present the financial position or changes in net position of the government. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The government has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the schedule) includes the federal award activity of the government under programs of the federal government for the year ended June 30, 2024. The Information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of the Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the government, it is not intended to and does not present the financial position or changes in net position of the government.
Title: NOTE 2 - SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the schedule) includes the federal award activity of the government under programs of the federal government for the year ended June 30, 2024. The Information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of the Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the government, it is not intended to and does not present the financial position or changes in net position of the government. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The government has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years
Title: NOTE 3 - INDIRECT COST RATES Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the schedule) includes the federal award activity of the government under programs of the federal government for the year ended June 30, 2024. The Information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of the Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the government, it is not intended to and does not present the financial position or changes in net position of the government. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The government has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The government has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance.
Title: NOTE 4 - DONATED PPE Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the schedule) includes the federal award activity of the government under programs of the federal government for the year ended June 30, 2024. The Information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of the Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the government, it is not intended to and does not present the financial position or changes in net position of the government. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The government has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. The estimated Fair Market Value (FMV) of donated PPE for the year ended June 30, 2024 was $0 (unaudited).
Title: NOTE 5 - PRIOR YEAR EXPENDITURES Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (the schedule) includes the federal award activity of the government under programs of the federal government for the year ended June 30, 2024. The Information in this schedule is presented in accordance with the requirements of Title 2 U.S. Code of the Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the schedule presents only a selected portion of the operations of the government, it is not intended to and does not present the financial position or changes in net position of the government. Expenditures reported on the schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The government has elected not to use the 10 percent de minimus indirect cost rate as allowed under the Uniform Guidance. Expenditures reported for Assistance Listing Number 20.106 - Airpport Improvement Program, include $50,000 in expenditures that were incurred in the prior year

Finding Details

SEGREGATION OF DUTIES Criteria: Duties should be segregated to provide reasonable assurance that transactions are handled appropriately. Condition: There is a lack of segregation of duties among personnel. Cause: There are a limited number of personnel for certain functions. Effect: Transactions could be mishandled. Recommendation: The duties should be separated as much as possible, and alternative controls should be used to compensate for lack of separation. The governing board should provide some of these controls. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318 through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214 prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not comply with the procurement standards outlined in 2 CFR §200.318-§200.327, which require competitive procurement processes and verification that contractors are not suspended or debarred. Specifically, the county did not verify the eligibility of program recipients/participants/contractors through the System for Award Management (SAM) or equivalent documentation in order to verify that they were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH SUBRECIPIENT MONITORING REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, GRANT No. AM-23-0211 Criteria: Per the 2024 OMB compliance supplement, subrecipient monitoring is required by pass-through entities for all SLFRF funded projects. Among other activities, Treasury considers the following activities to be part of subrecipient monitoring: • Ensuring that the subrecipient has access to information about public programs relevant to the subrecipient’s duties necessary to ensure that subaward performance goals are achieved. • Ensuring that the subrecipient has access to information about projects operated by other subrecipients, necessary to ensure that subaward performance goals are achieved. • Ensuring deliverables and payment are within the approved scope of the subaward. • Responding to inquiries about the interpretation of subrecipient responsibilities under the subaward • Processing and correcting invoices. • Taking remedial action necessary to prevent the subrecipient from failing to perform its responsibilities under the subaward. Condition: The county did perform subrecipient monitoring activities over the program as required by Treasury guidelines. Cause: The county does not have policies and procedures in place that allow it to comply with subrecipient monitoring requirements outlined in the Uniform Guidance and Treasury guidelines. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: The requirements for subrecipient monitoring for the subaward are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.332, and 200.501(h); federal awarding agency regulations; and the terms and conditions of the award. Management should develop procedures that will ensure compliance with the requirements. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
SEGREGATION OF DUTIES Criteria: Duties should be segregated to provide reasonable assurance that transactions are handled appropriately. Condition: There is a lack of segregation of duties among personnel. Cause: There are a limited number of personnel for certain functions. Effect: Transactions could be mishandled. Recommendation: The duties should be separated as much as possible, and alternative controls should be used to compensate for lack of separation. The governing board should provide some of these controls. Views of responsible officials and planned corrective actions: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, DIRECT ALLOCATION Criteria: Per section 13 of Treasury’s Final Rule FAQs and 2 CFR 200.214, counties must comply with the procurement standards set forth in 2 CFR 200.318 through 2 CFR 200.327, when using their SLFRF award funds to procure goods and services to carry out the objectives of their SLFRF award. In addition, 2 CFR 200.214 prohibits recipients from using SLFRF funds to enter into subawards and contracts with parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs. Condition: The county did not comply with the procurement standards outlined in 2 CFR §200.318-§200.327, which require competitive procurement processes and verification that contractors are not suspended or debarred. Specifically, the county did not verify the eligibility of program recipients/participants/contractors through the System for Award Management (SAM) or equivalent documentation in order to verify that they were not suspended, debarred, or otherwise excluded from participation in the program. Cause: The county does not have procurement policies and procedures in place that allow it to comply with procurement standards outlined in the Uniform Guidance. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: Management should develop procedures that will provide reasonable assurance that procurement of goods and services are made in compliance with applicable federal regulations and other procurement requirements specific to a federal award or subaward, and that no subaward, contract, or agreement for purchase of goods or services is made with any suspended or debarred party. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.
NONCOMPLIANCE WITH SUBRECIPIENT MONITORING REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, GRANT No. AM-23-0211 Criteria: Per the 2024 OMB compliance supplement, subrecipient monitoring is required by pass-through entities for all SLFRF funded projects. Among other activities, Treasury considers the following activities to be part of subrecipient monitoring: • Ensuring that the subrecipient has access to information about public programs relevant to the subrecipient’s duties necessary to ensure that subaward performance goals are achieved. • Ensuring that the subrecipient has access to information about projects operated by other subrecipients, necessary to ensure that subaward performance goals are achieved. • Ensuring deliverables and payment are within the approved scope of the subaward. • Responding to inquiries about the interpretation of subrecipient responsibilities under the subaward • Processing and correcting invoices. • Taking remedial action necessary to prevent the subrecipient from failing to perform its responsibilities under the subaward. Condition: The county did perform subrecipient monitoring activities over the program as required by Treasury guidelines. Cause: The county does not have policies and procedures in place that allow it to comply with subrecipient monitoring requirements outlined in the Uniform Guidance and Treasury guidelines. Effect: Non-compliance with program terms and conditions. Questioned Costs: None Recommendation: The requirements for subrecipient monitoring for the subaward are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.332, and 200.501(h); federal awarding agency regulations; and the terms and conditions of the award. Management should develop procedures that will ensure compliance with the requirements. Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.