Document Policies and Procedures Over Federal Awards
Federal Program Information
Federal Agency: U.S. Department of Treasury
Award Name(s): COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number(s): 21.027
Award Year: 2021
Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring
Type of Finding
Compliance
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement
OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Employee travel
• Cash management
• Procurement
• Conflicts of interest
• Subrecipient monitoring and management
Condition and Context
The County does not have written policies and procedures related to federal awards, as required under the Uniform Guidance.
Cause
The County has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance.
Effect or Potential Effect
Due to the weaknesses in internal controls noted above, the County did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature.
Recommendation
The County should address the weakness noted above and create policies and procedures related to federal awards in order to comply with the Uniform Guidance.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Internal Controls Over Reporting
Federal Program Information
Federal Agency: U.S. Department of Treasury
Award Name(s): COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number(s): 21.027
Award Year: 2021
Compliance Requirement: Reporting
Type of Finding
Compliance
Internal Control over Compliance – Material Weakness
Criteria or Specific Requirement
Grantees are required to file project and expenditure reports – report on financial data, projects funded, expenditures, and contracts and subawards over $50,000, and other information. Project and expenditure reports are due on a regular, recurring basis after the interim reports. The reporting frequency and deadlines vary by type of recipient and total allocation amount. Management is also responsible for establishing and maintaining effective internal controls over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context
There is no documented review of the interim report and project and expenditure reports by an individual that is not involved with preparing the reports. One individual is both preparing and reviewing the reports with no additional documented oversight. Additionally, key line items, specifically current period expenditures and total cumulative expenditures, included on the project and expenditure report submitted for quarters 2-4 of 2021 (March – December) did not agree to the general ledger, as required by the terms of the grant agreement.
Cause
Weakness in the design and implementation of internal controls.
Effect or Potential Effect
Due to the weaknesses in internal controls noted above, key line items on reports submitted may not be complete or accurate. No questioned costs are reported as they are not quantifiable.
Recommendation
The County should address the weakness in internal controls noted above by requiring two individuals to be involved in preparing and reviewing reports submitted to federal agencies to ensure the reports are complete and accurate.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Timely Filing of Single Audit Report
Type of Finding
Other Matter
Criteria or Specific Requirement
According to 2 CFR 200.512(a) of the Uniform Guidance, auditees are required to submit the audit report and Data Collection Form (DCF) to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after the reports are received from the auditor or nine months after the end of the audit period.
Condition and Context
The DCF has not been submitted by its due date of September 30, 2022.
Cause
Delays in the federal single audit process led to the delay in the federal single audit being completed.
Effect or Potential Effect
Delays in the single audit resulted in the FAC deadline being missed. Failure to submit the single audit report timely constitutes noncompliance with federal audit requirements. No questioned costs are reported as this requirement is administrative in nature.
Recommendation
The County should implement formal internal control policies and procedures to rectify the conditions noted above.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Document Policies and Procedures Over Federal Awards
Federal Program Information
Federal Agency: U.S. Department of Treasury
Award Name(s): COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number(s): 21.027
Award Year: 2021
Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Cash Management, Procurement, Subrecipient Monitoring
Type of Finding
Compliance
Internal Control over Compliance – Significant Deficiency
Criteria or Specific Requirement
OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requirements stipulate that federal award recipients must document their policies and procedures over certain aspects of financial and program management. Specifically, written policies are required for the following:
• Determination of allowable costs
• Employee travel
• Cash management
• Procurement
• Conflicts of interest
• Subrecipient monitoring and management
Condition and Context
The County does not have written policies and procedures related to federal awards, as required under the Uniform Guidance.
Cause
The County has not developed written formal documentation of internal controls to encompass all required areas per the Uniform Guidance.
Effect or Potential Effect
Due to the weaknesses in internal controls noted above, the County did not comply with the requirements of the Uniform Guidance over documented policies and procedures. No questioned costs are reported as this requirement is procedural in nature.
Recommendation
The County should address the weakness noted above and create policies and procedures related to federal awards in order to comply with the Uniform Guidance.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Internal Controls Over Reporting
Federal Program Information
Federal Agency: U.S. Department of Treasury
Award Name(s): COVID-19 – Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number(s): 21.027
Award Year: 2021
Compliance Requirement: Reporting
Type of Finding
Compliance
Internal Control over Compliance – Material Weakness
Criteria or Specific Requirement
Grantees are required to file project and expenditure reports – report on financial data, projects funded, expenditures, and contracts and subawards over $50,000, and other information. Project and expenditure reports are due on a regular, recurring basis after the interim reports. The reporting frequency and deadlines vary by type of recipient and total allocation amount. Management is also responsible for establishing and maintaining effective internal controls over compliance with federal requirements that have a direct and material effect on a federal program. A deficiency in internal control over compliance exists when the design or operation of a control over compliance does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, noncompliance with a type of compliance requirement of a federal program on a timely basis.
Condition and Context
There is no documented review of the interim report and project and expenditure reports by an individual that is not involved with preparing the reports. One individual is both preparing and reviewing the reports with no additional documented oversight. Additionally, key line items, specifically current period expenditures and total cumulative expenditures, included on the project and expenditure report submitted for quarters 2-4 of 2021 (March – December) did not agree to the general ledger, as required by the terms of the grant agreement.
Cause
Weakness in the design and implementation of internal controls.
Effect or Potential Effect
Due to the weaknesses in internal controls noted above, key line items on reports submitted may not be complete or accurate. No questioned costs are reported as they are not quantifiable.
Recommendation
The County should address the weakness in internal controls noted above by requiring two individuals to be involved in preparing and reviewing reports submitted to federal agencies to ensure the reports are complete and accurate.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.
Timely Filing of Single Audit Report
Type of Finding
Other Matter
Criteria or Specific Requirement
According to 2 CFR 200.512(a) of the Uniform Guidance, auditees are required to submit the audit report and Data Collection Form (DCF) to the Federal Audit Clearinghouse (FAC) within the earlier of 30 calendar days after the reports are received from the auditor or nine months after the end of the audit period.
Condition and Context
The DCF has not been submitted by its due date of September 30, 2022.
Cause
Delays in the federal single audit process led to the delay in the federal single audit being completed.
Effect or Potential Effect
Delays in the single audit resulted in the FAC deadline being missed. Failure to submit the single audit report timely constitutes noncompliance with federal audit requirements. No questioned costs are reported as this requirement is administrative in nature.
Recommendation
The County should implement formal internal control policies and procedures to rectify the conditions noted above.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.